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Home My WebLink AboutDAQ-2024-007426 DAQE-AN101520031-24 {{$d1 }} Jeff Schmidt Northrop Grumman Systems Corporation 2211 West North Temple Salt Lake City, UT 84116 j.schmidt@ngc.com Dear Mr. Schmidt: Re: Approval Order: Modification to Approval Order DAQE-AN101520030-24 to Add Equipment Project Number: N101520031 The attached Approval Order (AO) is issued pursuant to the Notice of Intent (NOI) received on December 15, 2023. Northrop Grumman Systems Corporation must comply with the requirements of this AO, all applicable state requirements (R307), and Federal Standards. The project engineer for this action is Christine Bodell, who can be contacted at (385) 290-2690 or cbodell@utah.gov. Future correspondence on this AO should include the engineer's name as well as the DAQE number shown on the upper right-hand corner of this letter. No public comments were received on this action. Sincerely, {{$s }} Bryce C. Bird Director BCB:CB:jg cc: Davis County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 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 March 13, 2024 STATE OF UTAH Department of Environmental Quality Division of Air Quality {{#s=Sig_es_:signer1:signature}} {{#d1=date1_es_:signer1:date:format(date, "mmmm d, yyyy")}} {{#d2=date1_es_:signer1:date:format(date, "mmmm d, yyyy"):align(center)}} APPROVAL ORDER DAQE-AN101520031-24 Modification to Approval Order DAQE-AN101520030-24 to Add Equipment Prepared By Christine Bodell, Engineer (385) 290-2690 cbodell@utah.gov Issued to Northrop Grumman Systems Corporation - Clearfield Freeport Center Issued On {{$d2 }} Issued By {{$s }} Bryce C. Bird Director Division of Air Quality March 13, 2024 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 ..................................................................................... 9 PERMIT HISTORY ................................................................................................................... 14 ACRONYMS ............................................................................................................................... 15 DAQE-AN101520031-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Northrop Grumman Systems Corporation Northrop Grumman Systems Corporation - Clearfield Freeport Center Mailing Address Physical Address 2211 West North Temple Freeport Center 13th Street Salt Lake City, UT 84116 Clearfield, UT 84016 Source Contact UTM Coordinates Name: Jeff Schmidt 414,000 m Easting Phone: (801) 774-4171 4,550,000 m Northing Email: j.schmidt@ngc.com Datum NAD83 UTM Zone 12 SIC code 3728 (Aircraft Parts & Auxiliary Equipment, NEC) SOURCE INFORMATION General Description Northrop Grumman Systems Corporation (Northrop) manufactures aerospace composite structures, specifically for commercial and defense contractors, at their Freeport Center plant located in Clearfield, Davis County. General steps in the manufacturing process include the following: raw material receipt and storage; material and tool preparation; fabrication; curing; finishing; testing; and packaging and shipping. As part of these steps, Northrop uses natural gas-fired equipment, including curing ovens, boilers, burners, hot rooms, autoclaves, and heated paint booths; operates dust collectors for control of various machining processes; has painting and welding operations; has various natural gas-fired and diesel-fired emergency generators; and has various laboratory and chemical mixing operations. NSR Classification Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Davis County Airs Source Size: B 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 DAQE-AN101520031-24 Page 4 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), WWWWWW: National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations Project Description Northrop has requested a modification to AO DAQE-AN101520030-24 to add one (1) electric kiln, one (1) electric oven, one (1) natural gas-fired oven rated at 1 MMBtu/hr, one (1) spray booth, and one (1) EPM receiving exhaust hood. Northrop has also proposed the removal of the HR-3 hot room, the SB-2 laboratory hood, the E-145 exhaust hood, and the DC-28 dust collector due to decommissioning. The equipment IDs of the removed equipment are II.A.4, II.A.9, II.A.10, and II.A.17 (respectively) in AO DAQE-AN101520030-24. 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 464 24709.00 Carbon Monoxide 0.34 16.72 Nitrogen Oxides 0.39 19.88 Particulate Matter - PM10 -0.26 13.16 Particulate Matter - PM2.5 -0.26 12.95 Sulfur Dioxide 0 0.15 Volatile Organic Compounds 0 69.00 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) 1,1,2-Trichloroethane (CAS #79005) 0 4000 2-(2-Butoxyethoxy)-Ethanol (CAS #112345) 0 4000 Chromium Compounds (CAS #CMJ500) 0 27 Cumene (CAS #98828) 0 4000 Ethyl Acrylate (CAS #140885) 0 4000 Ethyl Benzene (CAS #100414) 0 4000 Ethylene Glycol (CAS #107211) 0 4000 Formaldehyde (CAS #50000) 0 1000 Generic HAPs (CAS #GHAPS) 0 2000 Glycol Ethers (CAS #EDF109) 0 4000 Hexamethylene-1,6-Diisocyanate (CAS #822060) 0 14 Hexane (CAS #110543) 0 4000 Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 0 20 Methanol (CAS #67561) 0 4000 Methyl Chloroform (1,1,1-Trichloroethane) (CAS #71556) 0 19000 DAQE-AN101520031-24 Page 5 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 4000 Methyl Isocyanate (CAS #624839) 0 20 Methyl Methacrylate (CAS #80626) 0 200 Methylene Chloride (Dichloromethane) (CAS #75092) 0 4000 Methylene Diphenyl Diisocyanate (MDI) (CAS #101688) 0 20 Naphthalene (CAS #91203) 0 4000 Nickel Compounds (CAS #NDB000) 0 40 Phenol (CAS #108952) 0 4000 Styrene (CAS #100425) 0 200 Tetrachloroethylene (Perchloroethylene) (CAS #127184) 0 4000 Toluene (CAS #108883) 0 4000 Trichloroethylene (CAS #79016) 0 4000 Xylenes (Isomers And Mixture) (CAS #1330207) 0 4000 Change (TPY) Total (TPY) Total HAPs 0 45.27 SECTION I: GENERAL PROVISIONS I.1 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] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 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.4 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.5 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.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] DAQE-AN101520031-24 Page 6 I.8 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] SECTION II: PERMITTED EQUIPMENT II.A THE APPROVED EQUIPMENT II.A.1 Northrop Grumman Systems Corporation Aerospace composite components manufacturing facility II.A.2 Six (6) Electric Curing Ovens Ovens: O-21; O-36; O-48; O-159; O-160, IR&D Oven (New) II.A.3 One (1) IR&D Electric Kiln New II.A.4 Twelve (12) Natural Gas-Fired Ovens Oven: Rating: O-26 1.2 MMBtu/hr O-27 4.0 MMBtu/hr COV1 2.8 MMBtu/hr COV2 4.0 MMBtu/hr O-30 3.5 MMBtu/hr O-22 2.0 MMBtu/hr O-24 0.6 MMBtu/hr O-37 3.0 MMBtu/hr O-39 6.4 MMBtu/hr O-41 1.0 MMBtu/hr O-47 3.0 MMBtu/hr O-52 1 MMBtu/hr (New) II.A.5 Six (6) Hot Rooms Rooms: ACU253, AHU1, AHU2, AHU3, AHU4, HR1 Fuel: Natural Gas Maximum Rating: < 5.0 MMBtu/hr (each) II.A.6 One (1) Boiler- BO1 Fuel: Natural Gas Rating: 8.37 MMBtu/hr II.A.7 Three (3) Autoclaves Autoclave: Rating: AC1 12.0 MMBtu/hr AC6 24.3 MMBtu/hr AC12 15.0 MMBtu/hr Fuel: Natural Gas DAQE-AN101520031-24 Page 7 II.A.8 Five (5) Autoclaves Autoclaves: CAC1, CAC2, CAC3, CAC4, CAC5 Fuel: Natural Gas Rating: 15.8 MMBtu/hr (each) II.A.9 Twelve (12) Ventilation Rooms Ten (10) Mandrel Prep Rooms; FX-141; Paint Touchup Room II.A.10 Ten (10) Laboratory Hoods FUH-3; FUH-7; AT-401073; FUH-5; FUH-2; AT-401706; FE-200; FE-222; FUH-1; 2228 II.A.11 Thirteen (13) Exhaust Hoods 1,2. Two (2) Welding fume exhausters 3. RMS-6 4. Battery Charging area exhaust hood 5. MX-85 6. M-5 7. 83310J00475 8. FX-105 9. FX-106 10. FE-655 11, 12. Two (2) Paint mixing fume hoods 13. EPM Receiving (New) II.A.12 Four (4) Heated Paint Booths Paint Booth: Heater Rating: SB10 750 KBtu/hr SB11 950 KBtu/hr SB12 950 KBtu/hr SB13 950 KBtu/hr Fuel: Natural Gas II.A.13 Seven (7) Spray Booths SB7, SB9, SB5, SB14, IFE SB, Topcoat SB, SB (New) Control: Fabric Filters (each) II.A.14 One (1) Ceramics Spray Booth Control: High efficiency 3-stage fabric filters II.A.15 One (1) Thermal Spray Booth Control: Pulse jet baghouse (DC-58) Baghouse Maximum Flow Rate: 25,300 acfm MACT Applicability: Subpart WWWWWW DAQE-AN101520031-24 Page 8 II.A.16 Eight (8) Natural Gas-Fired Emergency Generators Engine: Rating: GE 3 7 kW GE 4 35 kW GE 5 100 kW GE 8 80 kW GE 9 240 kW NSPS Applicability: None MACT Applicability: Subpart ZZZZ Engine: Rating: GE 10 45 kW GE 11 45 kW GE 12 85 kW NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.17 Two (2) Diesel-Fired Emergency Generators Engine: GE 7 Rating: 225 kW Engine: GE 13 Rating: 268 hp NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.18 Seven (7) Dust Collectors DC-16, DC-27, DC-29, DC-30, DC-36, DC-37, DC-38 II.A.19 Miscellaneous Equipment Miscellaneous vacuum pumps Miscellaneous Air compressors II.A.20 Miscellaneous Combustion Equipment Various Boilers and Heaters Maximum Rating: <5.0 MMBtu/hr Fuel: Natural Gas II.A.21 Eighteen (18) Wet Cooling Towers CT-6, CT-7, CT-9, CT-13, CT-14, CT-15, CT-16, CT-17, CT-18, CT-19, CT-20, CT-21, CT-22, CT-23, CT-24, CT-25, CT-26, CT-27 Controls: High Efficiency Drift Eliminators (each) DAQE-AN101520031-24 Page 9 II.A.22 Informational-Only Equipment* Nineteen (19) electrical sample curing ovens One (1) electrical Hot room Eight (8) electrical autoclaves One (1) Buffer room Miscellaneous Dust Collectors, including portable and orifice scrubbers Miscellaneous Machining Centers / Lathes / Cork Cutting Equipment One (1) Spray Gun Cleaning Station Miscellaneous Grit Blast and Abrading Equipment 3D Printers *This equipment vents internally and is listed for informational purposes only II.A.23 Informational-Only Equipment* (Continued) Three (3) Hot Drape Forming Machines One (1) Ductless Fume Hood Two (2) Reticulators Two (2) Dry Cooling Towers *This equipment vents internally and is listed for informational purposes only II.A.24 Grandfathered Equipment* Pit exhaust system Indirect gas fired curing oven - #20 Rating: 6 MMBtu/hr *This equipment was installed before 1969 and is listed for informational purposes only SECTION II: SPECIAL PROVISIONS II.B REQUIREMENTS AND LIMITATIONS II.B.1 Site-Wide 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 engines - 20% opacity. B. All other emission points - 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall not exceed a plant-wide natural gas consumption limit of 406,624 Decatherms per rolling 12-month period. [R307-401-8] DAQE-AN101520031-24 Page 10 II.B.1.b.1 The owner/operator shall: A. Determine consumption by gas billing records. B. Record consumption on a monthly basis. C. Use the consumption records to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months. D. Keep consumption records for all periods the plant is in operation. [R307-401-8] II.B.1.c The owner/operator shall comply with all applicable requirements of UAC R307-325 (Ozone Nonattainment and Maintenance Areas: General Requirements) and UAC R307-355 (Control of Emissions from Aerospace Manufacture and Rework Facilities), [R307-355] DAQE-AN101520031-24 Page 11 II.B.2 VOC & HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from all sources on site: A. 69.00 tons per rolling 12-month period of VOCs. B. 19.00 tons per rolling 12-month period of all HAPs combined. C. 2.00 tons per rolling 12-month period of 2-Butoxyethanol. D. 0.014 tons per rolling 12-month period of Chromium Compounds. E. 2.00 tons per rolling 12-month period of Cumene. F. 2.00 tons per rolling 12-month period of Ethyl Acrylate. G. 2.00 tons per rolling 12-month period of Ethylbenzene. H. 2.00 tons per rolling 12-month period of Ethylene Glycol. I. 0.50 tons per rolling 12-month period of Formaldehyde. J. 2.00 tons per rolling 12-month period of Glycol Ethers. K. 0.007 tons per rolling 12-month period of Hexamethylene-1,6-Diisocyanate. L. 2.00 tons per rolling 12-month period of Hexane. M. 0.010 tons per rolling 12-month period of Hydrogen Fluoride. N. 2.00 tons per rolling 12-month period of Methyl Alcohol. O. 0.010 tons per rolling 12-month period of Methyl Isocyanate. P. 2.00 tons per rolling 12-month period of Methylene Chloride. Q. 0.10 tons per rolling 12-month period of Methylenedianiline. R. 0.010 tons per rolling 12-month period of Methylene Diphenyl Diisocyanate. S. 2.00 tons per rolling 12-month period of Methyl Isobutyl Ketone (MIBK). T. 2.00 tons per rolling 12-month period of Naphthalene. [R307-401-8] DAQE-AN101520031-24 Page 12 II.B.2.a The owner/operator shall not emit more than the following from all sources on site continued: U. 0.02 tons per rolling 12-month period of Nickel Compounds. V. 2.00 tons per rolling 12-month period of Phenol. W. 2.00 tons per rolling 12-month period of Tetrachloroethylene. X. 2.00 tons per rolling 12-month period of Toluene. Y. 9.50 tons per rolling 12-month period of 1,1,1-Trichloroethane. Z. 2.00 tons per rolling 12-month period of 1,1,2-Trichloroethane. AA. 2.00 tons per rolling 12-month period of Trichloroethylene. BB. 2.00 tons per rolling 12-month period of Xylene. CC. 1.20 tons per rolling 12-month period of any other HAPs combined. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] Non-Metal HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] Metal HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] x [filter control efficiency] [R307-401-8] II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] DAQE-AN101520031-24 Page 13 II.B.2.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material. B. The maximum percent by weight of VOCs and each HAP in each material used. C. The density of each material used. D. The volume of each VOC- and HAP-emitting material used. E. The amount of VOCs and the amount of each HAP emitted from each material. F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material. G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] II.B.3 Paint Booth Requirements II.B.3.a The owner/operator shall equip each paint booth with paint arrestor particulate filters to control particulate emissions. All exhaust air from the paint booths shall be routed through the filters before venting to the atmosphere. [R307-401-8] II.B.3.b The paint booths shall be equipped with HVLP spray guns, or an equivalent method, to control VOC emissions. [R307-355-6] II.B.3.c The owner/operator shall control the thermal spray booth with a baghouse. [R307-401-8] II.B.3.d The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across the thermal spray booth baghouse. The baghouse shall operate within the static pressure range recommended by the manufacturer for normal operations. [R307-401-8] II.B.3.d.1 Pressure drop readings shall be recorded at least once during each day of operation while the baghouse is operating. Records documenting the pressure drop shall be kept in a log and shall include the following: A. Unit identification. B. Manufacturer-recommended pressure drop for the unit. C. Daily pressure drop readings. D. Date of reading. [R307-401-8] II.B.3.d.2 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.3.d.3 The instrument shall be calibrated in accordance with the manufacturer's instructions or recommendations or replaced at least once every 12 months. Documentation of calibrations and replacements shall be maintained. [R307-401-8] DAQE-AN101520031-24 Page 14 II.B.4 Emergency Engine Requirements II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per calendar year during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.a.1 To determine compliance with a calendar year total, the owner/operator shall calculate a new yearly total by January 31st using data from the previous calendar 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. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5 Fuel Requirements II.B.5.a The owner/operator shall use only natural gas as a fuel in all fuel-burning furnaces, ovens, boilers, heaters, and natural gas-fired emergency engines. [R307-401-8] II.B.5.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the diesel-fired emergency engines. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD) and contain no more than 15 ppm sulfur. [R307-401-8] II.B.5.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN101520030-24 dated January 18, 2024 Is Derived From NOI dated December 15, 2023 DAQE-AN101520031-24 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 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-IN101520031-24 February 5, 2024 Jeff Schmidt Northrop Grumman Systems Corporation 2211 West North Temple Salt Lake City, UT 84116 j.schmidt@ngc.com Dear Mr. Schmidt: Re: Intent to Approve: Modification to Approval Order DAQE-AN101520030-24 to Add Equipment Project Number: N101520031 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, Christine Bodell, as well as the DAQE number as shown on the upper right-hand corner of this letter. Christine Bodell, can be reached at (385) 290-2690 or cbodell@utah.gov, if you have any questions. Sincerely, {{$s }} Alan D. Humpherys, Manager New Source Review Section ADH:CB:jg cc: Davis County Health Department 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144820 • Salt Lake City, UT 84114-4820 Telephone (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper State of Utah SPENCER J. COX Governor DEIDRE HENDERSON Lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF AIR QUALITY Bryce C. Bird Director STATE OF UTAH Department of Environmental Quality Division of Air Quality INTENT TO APPROVE DAQE-IN101520031-24 Modification to Approval Order DAQE-AN101520030-24 to Add Equipment Prepared By Christine Bodell, Engineer (385) 290-2690 cbodell@utah.gov Issued to Northrop Grumman Systems Corporation - Clearfield Freeport Center Issued On February 5, 2024 {{$s }} New Source Review Section Manager Alan D. Humpherys {{#s=Sig_es_:signer1:signature}} TABLE OF CONTENTS TITLE/SIGNATURE PAGE ....................................................................................................... 1 FGENERAL 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 ..................................................................................... 9 PERMIT HISTORY ................................................................................................................... 14 ACRONYMS ............................................................................................................................... 15 DAQE-IN101520031-24 Page 3 GENERAL INFORMATION CONTACT/LOCATION INFORMATION Owner Name Source Name Northrop Grumman Systems Corporation Northrop Grumman Systems Corporation - Clearfield Freeport Center Mailing Address Physical Address 2211 West North Temple Freeport Center 13th Street Salt Lake City, UT 84116 Clearfield, UT 84016 Source Contact UTM Coordinates Name: Jeff Schmidt 414,000 m Easting Phone: (801) 774-4171 4,550,000 m Northing Email: j.schmidt@ngc.com Datum NAD83 UTM Zone 12 SIC code 3728 (Aircraft Parts & Auxiliary Equipment, NEC) SOURCE INFORMATION General Description Northrop Grumman Systems Corporation (Northrop) manufactures aerospace composite structures, specifically for commercial and defense contractors, at their Freeport Center plant located in Clearfield, Davis County. General steps in the manufacturing process include the following: raw material receipt and storage, material and tool preparation, fabrication, curing, finishing, testing, and packaging and shipping. As part of these steps, Northrop uses natural gas-fired equipment including curing ovens, boilers, burners, hot rooms, autoclaves, and heated paint booths; operates dust collectors for control of various machining processes; has painting and welding operations; has various natural gas-fired and diesel-fired emergency generators; and has various laboratory and chemical mixing operations. NSR Classification Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Davis County Airs Source Size: B 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-IN101520031-24 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), WWWWWW: National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations Project Description Northrop has requested a modification to AO DAQE-AN101520030-24 to add one (1) electric kiln, one (1) electric oven, one (1) natural gas-fired oven rated at 1 MMBtu/hr, one (1) spray booth, and one (1) EPM receiving exhaust hood. Northrop has also proposed the removal of the HR-3 hot room, the SB-2 laboratory hood, the E-145 exhaust hood, and the DC-28 dust collector due to decommissioning. The Equipment IDs of the removed equipment are II.A.4, II.A.9, II.A.10, and II.A.17 (respectively) in AO DAQE-AN101520030-24. 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 464 24709.00 Carbon Monoxide 0.34 16.72 Nitrogen Oxides 0.39 19.88 Particulate Matter - PM10 -0.26 13.16 Particulate Matter - PM2.5 -0.26 12.95 Sulfur Dioxide 0 0.15 Volatile Organic Compounds 0 69.00 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) 1,1,2-Trichloroethane (CAS #79005) 0 4000 2-(2-Butoxyethoxy)-Ethanol (CAS #112345) 0 4000 Chromium Compounds (CAS #CMJ500) 0 27 Cumene (CAS #98828) 0 4000 Ethyl Acrylate (CAS #140885) 0 4000 Ethyl Benzene (CAS #100414) 0 4000 Ethylene Glycol (CAS #107211) 0 4000 Formaldehyde (CAS #50000) 0 1000 Generic HAPs (CAS #GHAPS) 0 2000 Glycol Ethers (CAS #EDF109) 0 4000 Hexamethylene-1,6-Diisocyanate (CAS #822060) 0 14 Hexane (CAS #110543) 0 4000 Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 0 20 Methanol (CAS #67561) 0 4000 Methyl Chloroform (1,1,1-Trichloroethane) (CAS #71556) 0 19000 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 4000 Methyl Isocyanate (CAS #624839) 0 20 Methyl Methacrylate (CAS #80626) 0 200 DAQE-IN101520031-24 Page 5 Methylene Chloride (Dichloromethane) (CAS #75092) 0 4000 Methylene Diphenyl Diisocyanate (MDI) (CAS #101688) 0 20 Naphthalene (CAS #91203) 0 4000 Nickel Compounds (CAS #NDB000) 0 40 Phenol (CAS #108952) 0 4000 Styrene (CAS #100425) 0 200 Tetrachloroethylene (Perchloroethylene) (CAS #127184) 0 4000 Toluene (CAS #108883) 0 4000 Trichloroethylene (CAS #79016) 0 4000 Xylenes (Isomers And Mixture) (CAS #1330207) 0 4000 Change (TPY) Total (TPY) Total HAPs 0 45.27 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 Ogden Standard Examiner on February 6, 2024. 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 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] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 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.4 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] DAQE-IN101520031-24 Page 6 I.5 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.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307-150] I.8 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] 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 Northrop Grumman Systems Corporation Aerospace composite components manufacturing facility II.A.2 Six (6) Electric Curing Ovens Ovens: O-21; O-36; O-48; O-159; O-160, IR&D Oven (New) II.A.3 One (1) IR&D Electric Kiln New II.A.4 Twelve (12) Natural Gas-Fired Ovens Oven: Rating: O-26 1.2 MMBtu/hr O-27 4.0 MMBtu/hr COV1 2.8 MMBtu/hr COV2 4.0 MMBtu/hr O-30 3.5 MMBtu/hr O-22 2.0 MMBtu/hr O-24 0.6 MMBtu/hr O-37 3.0 MMBtu/hr O-39 6.4 MMBtu/hr O-41 1.0 MMBtu/hr O-47 3.0 MMBtu/hr O-52 1 MMBtu/hr (New) DAQE-IN101520031-24 Page 7 II.A.5 Six (6) Hot Rooms Rooms: ACU253, AHU1, AHU2, AHU3, AHU4, HR1 Fuel: Natural Gas Maximum Rating: < 5.0 MMBtu/hr (each) II.A.6 One (1) Boiler- BO1 Fuel: Natural Gas Rating: 8.37 MMBtu/hr II.A.7 Three (3) Autoclaves Autoclave: Rating: AC1 12.0 MMBtu/hr AC6 24.3 MMBtu/hr AC12 15.0 MMBtu/hr Fuel: Natural Gas II.A.8 Five (5) Autoclaves Autoclaves: CAC1, CAC2, CAC3, CAC4, CAC5 Fuel: Natural Gas Rating: 15.8 MMBtu/hr (each) II.A.9 Twelve (12) Ventilation Rooms Ten (10) Mandrel Prep Rooms; FX-141; Paint Touchup Room II.A.10 Ten (10) Laboratory Hoods FUH-3; FUH-7; AT-401073; FUH-5; FUH-2; AT-401706; FE-200; FE-222; FUH-1; 2228 II.A.11 Thirteen (13) Exhaust Hoods 1,2. Two (2) Welding fume exhausters 3. RMS-6 4. Battery Charging area exhaust hood 5. MX-85 6. M-5 7. 83310J00475 8. FX-105 9. FX-106 10. FE-655 11, 12. Two (2) Paint mixing fume hoods 13. EPM Receiving (New) II.A.12 Four (4) Heated Paint Booths Paint Booth: Heater Rating: SB10 750 KBtu/hr SB11 950 KBtu/hr SB12 950 KBtu/hr SB13 950 KBtu/hr Fuel: Natural Gas II.A.13 Seven (7) Spray Booths SB7, SB9, SB5, SB14, IFE SB, Topcoat SB, SB (New) Control: Fabric Filters (each) DAQE-IN101520031-24 Page 8 II.A.14 One (1) Ceramics Spray Booth Control: High efficiency 3-stage fabric filters II.A.15 One (1) Thermal Spray Booth Control: Pulse jet baghouse (DC-58) Baghouse Maximum Flow Rate: 25,300 acfm MACT Applicability: Subpart WWWWWW II.A.16 Eight (8) Natural Gas-Fired Emergency Generators Engine: Rating: GE 3 7 kW GE 4 35 kW GE 5 100 kW GE 8 80 kW GE 9 240 kW NSPS Applicability: None MACT Applicability: Subpart ZZZZ Engine: Rating: GE 10 45 kW GE 11 45 kW GE 12 85 kW NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.17 Two (2) Diesel-Fired Emergency Generators Engine: GE 7 Rating: 225 kW Engine: GE 13 Rating: 268 hp NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.18 Seven (7) Dust Collectors DC-16, DC-27, DC-29, DC-30, DC-36, DC-37, DC-38 II.A.19 Miscellaneous Equipment Miscellaneous vacuum pumps Miscellaneous Air compressors II.A.20 Miscellaneous Combustion Equipment Various Boilers and Heaters Maximum Rating: <5.0 MMBtu/hr Fuel: Natural Gas II.A.21 Eighteen (18) Wet Cooling Towers CT-6, CT-7, CT-9, CT-13, CT-14, CT-15, CT-16, CT-17, CT-18, CT-19, CT-20, CT-21, CT-22, CT-23, CT-24, CT-25, CT-26, CT-27 Controls: High Efficiency Drift Eliminators (each) DAQE-IN101520031-24 Page 9 II.A.22 Informational-Only Equipment* Nineteen (19) electrical sample curing ovens One (1) electrical Hot room Eight (8) electrical autoclaves One (1) Buffer room Miscellaneous Dust Collectors, including portable and orifice scrubbers Miscellaneous Machining Centers / Lathes / Cork Cutting Equipment One (1) Spray Gun Cleaning Station Miscellaneous Grit Blast and Abrading Equipment 3D Printers *This equipment vents internally and is listed for informational purposes only II.A.23 Informational-Only Equipment* (Continued) Three (3) Hot Drape Forming Machines One (1) Ductless Fume Hood Two (2) Reticulators Two (2) Dry Cooling Towers *This equipment vents internally and is listed for informational purposes only II.A.24 Grandfathered Equipment* Pit exhaust system Indirect gas fired curing oven - #20 Rating: 6 MMBtu/hr *This equipment was installed before 1969 and is listed for informational purposes only 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 Site-Wide 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 engines - 20% opacity B. All other emission points - 10% opacity. [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] II.B.1.b The owner/operator shall not exceed a plant-wide natural gas consumption limit of 406,624 Decatherms per rolling 12-month period. [R307-401-8] DAQE-IN101520031-24 Page 10 II.B.1.b.1 The owner/operator shall: A. Determine consumption by gas billing records B. Record consumption on a monthly basis C. Use the consumption records to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep consumption records for all periods the plant is in operation. [R307-401-8] II.B.1.c The owner/operator shall comply with all applicable requirements of UAC R307-325 (Ozone Nonattainment and Maintenance Areas: General Requirements) and UAC R307-355 (Control of Emissions from Aerospace Manufacture and Rework Facilities), [R307-355] DAQE-IN101520031-24 Page 11 II.B.2 VOC & HAP Requirements II.B.2.a The owner/operator shall not emit more than the following from all sources on site: A. 69.00 tons per rolling 12-month period of VOCs B. 19.00 tons per rolling 12-month period of all HAPs combined C. 2.00 tons per rolling 12-month period of 2-Butoxyethanol D. 0.014 tons per rolling 12-month period of Chromium Compounds E. 2.00 tons per rolling 12-month period of Cumene F. 2.00 tons per rolling 12-month period of Ethyl Acrylate G. 2.00 tons per rolling 12-month period of Ethylbenzene H. 2.00 tons per rolling 12-month period of Ethylene Glycol I. 0.50 tons per rolling 12-month period of Formaldehyde J. 2.00 tons per rolling 12-month period of Glycol Ethers K. 0.007 tons per rolling 12-month period of Hexamethylene-1,6-Diisocyanate L. 2.00 tons per rolling 12-month period of Hexane M. 0.010 tons per rolling 12-month period of Hydrogen Fluoride M. 2.00 tons per rolling 12-month period of Methyl Alcohol O. 0.010 tons per rolling 12-month period of Methyl Isocyanate P. 2.00 tons per rolling 12-month period of Methylene Chloride Q. 0.10 tons per rolling 12-month period of Methylenedianiline R. 0.010 tons per rolling 12-month period of Methylene Diphenyl Diisocyanate S. 2.00 tons per rolling 12-month period of Methyl Isobutyl Ketone (MIBK) T. 2.00 tons per rolling 12-month period of Naphthalene. DAQE-IN101520031-24 Page 12 II.B.2.a The owner/operator shall not emit more than the following from all sources on site continued: U. 0.02 tons per rolling 12-month period of Nickel Compounds V. 2.00 tons per rolling 12-month period of Phenol W. 2.00 tons per rolling 12-month period of Tetrachloroethylene X. 2.00 tons per rolling 12-month period of Toluene Y. 9.50 tons per rolling 12-month period of 1,1,1-Trichloroethane Z. 2.00 tons per rolling 12-month period of 1,1,2-Trichloroethane AA. 2.00 tons per rolling 12-month period of Trichloroethylene BB. 2.00 tons per rolling 12-month period of Xylene CC. 1.20 tons per rolling 12-month period of any other HAPs combined. [R307-401-8] II.B.2.a.1 The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] Non-Metal HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] Metal HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] x [filter control efficiency] [R307-401-8] II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] DAQE-IN101520031-24 Page 13 II.B.2.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons). [R307-401-8] II.B.3 Paint Booth Requirements II.B.3.a The owner/operator shall equip each paint booth with paint arrestor particulate filters to control particulate emissions. All exhaust air from the paint booths shall be routed through the filters before venting to the atmosphere. [R307-401-8] II.B.3.b The paint booths shall be equipped with HVLP spray guns, or an equivalent method, to control VOC emissions. [R307-355-6] II.B.3.c The owner/operator shall control the thermal spray booth with a baghouse. [R307-401-8] II.B.3.d The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across the thermal spray booth baghouse. The baghouse shall operate within the static pressure range recommended by the manufacturer for normal operations. [R307-401-8] II.B.3.d.1 Pressure drop readings shall be recorded at least once during each day of operation while the baghouse is operating. Records documenting the pressure drop shall be kept in a log and shall include the following: A. Unit identification B. Manufacturer-recommended pressure drop for the unit C. Daily pressure drop readings D. Date of reading. [R307-401-8] II.B.3.d.2 The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] II.B.3.d.3 The instrument shall be calibrated in accordance with the manufacturer's instructions or recommendations or replaced at least once every 12 months. Documentation of calibrations and replacements shall be maintained. [R307-401-8] DAQE-IN101520031-24 Page 14 II.B.4 Emergency Engine Requirements II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per calendar year during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.a.1 To determine compliance with a calendar year total, the owner/operator shall calculate a new yearly total by January 31st using data from the previous calendar 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. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5 Fuel Requirements II.B.5.a The owner/operator shall use only natural gas as a fuel in all fuel-burning furnaces, ovens, boilers, heaters, and natural gas-fired emergency engines. [R307-401-8] II.B.5.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the diesel-fired emergency engines. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD) and contain no more than 15 ppm sulfur. [R307-401-8] II.B.5.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8] PERMIT HISTORY This Approval Order shall supersede (if a modification) or will be based on the following documents: Supersedes AO DAQE-AN101520030-24 dated January 18, 2024 Is Derived From NOI dated December 15, 2023 DAQE-IN101520031-24 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 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 Northrup Grumman 10152 0031 - Page 1 of 2 FILER Jeree Greenwood jereeg@utah.gov (801) 536-4000 FILING FOR Standard-Examiner Columns Wide:1 Total Column Inches:10.71 Number of Lines:86 Ad Class:Legals INTERIM AD DRAFT T h i s is t he p r oo f o f yo ur ad sc he du l e d to r u n in S t an d a rd -E xa m i n e r o n t he d a te s in dic ate d be l ow. If c h a n ge s a r e ne ed ed , p l ea se co nt a ct us pr i o r to d ea dlin e a t (8 01 ) 6 25 -4 30 2. Notice ID: 67kHl6DumAL4WFPEIYlv | Proof Updated: Feb. 05, 2024 at 09:38am MST Notice Name: Northrup Grumman 10152 0031 This is not an invoice. Below is an estimated price, and it is subject to change. You will receive an invoice with the final price upon invoice creation by the publisher. 02/06/2024: Custom 385.72 Base Affidavit Fee 12.00 Subtotal $397.72 Tax $0.00 Processing Fee $39.77 Total $437.49 See Proof on Next Page Northrup Grumman 10152 0031 - Page 2 of 2 DAQE-NN101520031-24 February 5, 2024 Ogden Standard Examiner Legal Advertising Department 332 Standard Way P.O. Box 12790 Ogden, Ut 84412 Acct # 100331 RE: Legal Notice of Intent to Approve This letter will confirm the authorization to publish the attached NOTICE in the Ogden Standard Examiner (Account Number: 100331) on February 6, 2024. Please mail the invoice and affidavit of publication to the Utah State Department of Environmental Quality, Division of Air Quality, P.O. Box 144820, Salt Lake City, Utah 84114-4820. If you have any questions, contact Jeree Greenwood, who may be reached at (385) 306-6514. Sincerely, {{$s }} Jeree Greenwood Office Technician Enclosure cc: Davis 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 (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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-NN101520031-24 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 - Clearfield Freeport Center – Freeport Center 13th Street, Clearfield, UT Project Description: Northrop Grumman Systems Corporation (Northrop) manufactures aerospace composite structures, specifically for commercial and defense contractors, at their Freeport Center plant located in Clearfield, Davis County. General steps in the manufacturing process include the following: raw material receipt and storage, material and tool preparation, fabrication, curing, finishing, testing, and packaging and shipping. As part of these steps, Northrop uses natural gas-fired equipment including curing ovens, boilers, burners, hot rooms, autoclaves, and heated paint booths; operates dust collectors for control of various machining processes; has painting and welding operations; has various natural gas-fired and diesel-fired emergency generators; and has various laboratory and chemical mixing operations. Northrop has requested a modification to Approval Order DAQE-AN101520030-24 to add one (1) electric kiln, one (1) electric oven, one (1) natural gas-fired oven rated at 1 MMBtu/hr, one (1) spray booth, and one (1) EPM receiving exhaust hood. Northrop has also proposed the removal of the HR- 3 hot room, the SB-2 laboratory hood, the E-145 exhaust hood, and the DC-28 dust collector due to decommissioning. The Equipment IDs of the removed equipment are II.A.4, II.A.9, II.A.10, and II.A.17 (respectively) in Approval Order DAQE-AN101520030-24. 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 March 7, 2024 will be considered in making the final decision on the approval/disapproval of the proposed project. Email comments will also be accepted at cbodell@utah.gov. 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: February 6, 2024 {{#s=Sig_es_:signer1:signature}} DAQE- RN101520031 January 24, 2024 Jeff Schmidt Northrop Grumman Systems Corporation 2211 West North Temple Salt Lake City, UT 84116 j.schmidt@ngc.com Dear Jeff Schmidt, Re: Engineer Review: Modification to Approval Order DAQE-AN101520030-24 to Add Equipment Project Number: N101520031 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 Christine Bodell at (385) 290-2690 if there are questions or concerns with the review of the draft permit conditions. Upon resolution of your concerns, please email Christine Bodell at cbodell@utah.gov 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 (801) 536-4000 • Fax (801) 536-4099 • T.D.D. (801) 903-3978 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 Lieutenant Governor Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 1 UTAH DIVISION OF AIR QUALITY ENGINEER REVIEW SOURCE INFORMATION Project Number N101520031 Owner Name Northrop Grumman Systems Corporation Mailing Address 2211 West North Temple Salt Lake City, UT, 84116 Source Name Northrop Grumman Systems Corp. - Clearfield Freeport Center Source Location Freeport Center 13th Street Clearfield, UT 84016 UTM Projection 414,000 m Easting, 4,550,000 m Northing UTM Datum NAD83 UTM Zone UTM Zone 12 SIC Code 3728 (Aircraft Parts & Auxiliary Equipment, NEC) Source Contact Jeff Schmidt Phone Number (801) 774-4171 Email j.schmidt@ngc.com Billing Contact Jeff Schmidt Phone Number 801-774-4171 Email j.schmidt@ngc.com Project Engineer Christine Bodell, Engineer Phone Number (385) 290-2690 Email cbodell@utah.gov Notice of Intent (NOI) Submitted December 15, 2023 Date of Accepted Application January 1, 2024 Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 2 SOURCE DESCRIPTION General Description Northrop Grumman Systems Corp. (Northrop) manufactures aerospace composite structures, specifically for commercial and defense contractors, at their Freeport Center plant located in Clearfield, Davis County. General steps in the manufacturing process include the following: raw material receipt and storage, material and tool preparation, fabrication, curing, finishing, testing, and packaging and shipping. As part of these steps, Northrop uses natural gas-fired equipment including curing ovens, boilers, burners, hot rooms, autoclaves, and heated paint booths; operates dust collectors for control of various machining processes; has painting and welding operations; has various natural gas-fired and diesel-fired emergency generators; and has various laboratory and chemical mixing operations. NSR Classification: Minor Modification at Minor Source Source Classification Located in Northern Wasatch Front O3 NAA, Salt Lake City UT PM2.5 NAA Davis County Airs Source Size: B 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), WWWWWW: National Emission Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations Project Proposal Modification to Approval Order DAQE-AN101520030-24 to Add Equipment Project Description Northrop Grumman Systems Corp. (Northrop) has requested a modification to AO DAQE- AN101520030-24 to add one (1) electric kiln, one (1) electric oven, one (1) natural gas-fired oven rated at 1 MMBtu/hr, one (1) spray booth, and one (1) EPM receiving exhaust hood. Northrop has also proposed the removal of the HR-3 hot room, the SB-2 laboratory hood, the E-145 exhaust hood, and the DC-28 dust collector due to decommissioning. The Equipment IDs of the removed equipment are II.A.4, II.A.9, II.A.10, and II.A.17 (respectively) in AO DAQE-AN101520030-24. EMISSION IMPACT ANALYSIS The criteria pollutant and HAP emission increases do not exceed any modeling thresholds as defined by Utah Administrative Code (UAC) R307-410. Therefore, modeling is not required for this modification. [Last updated December 21, 2023] Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 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 464 24709.00 Carbon Monoxide 0.34 16.72 Nitrogen Oxides 0.39 19.88 Particulate Matter - PM10 -0.26 13.16 Particulate Matter - PM2.5 -0.26 12.95 Sulfur Dioxide 0 0.15 Volatile Organic Compounds 0 69.00 Hazardous Air Pollutant Change (lbs/yr) Total (lbs/yr) 1,1,2-Trichloroethane (CAS #79005) 0 4000 2-(2-Butoxyethoxy)-Ethanol (CAS #112345) 0 4000 Chromium Compounds (CAS #CMJ500) 0 27 Cumene (CAS #98828) 0 4000 Ethyl Acrylate (CAS #140885) 0 4000 Ethyl Benzene (CAS #100414) 0 4000 Ethylene Glycol (CAS #107211) 0 4000 Formaldehyde (CAS #50000) 0 1000 Generic HAPs (CAS #GHAPS) 0 2000 Glycol Ethers (CAS #EDF109) 0 4000 Hexamethylene-1,6-Diisocyanate (CAS #822060) 0 14 Hexane (CAS #110543) 0 4000 Hydrogen Fluoride (Hydrofluoric Acid) (CAS #7664393) 0 20 Methanol (CAS #67561) 0 4000 Methyl Chloroform (1,1,1-Trichloroethane) (CAS #71556) 0 19000 Methyl Isobutyl Ketone (Hexone) (CAS #108101) 0 4000 Methyl Isocyanate (CAS #624839) 0 20 Methyl Methacrylate (CAS #80626) 0 200 Methylene Chloride (Dichloromethane) (CAS #75092) 0 4000 Methylene Diphenyl Diisocyanate (MDI) (CAS #101688) 0 20 Naphthalene (CAS #91203) 0 4000 Nickel Compounds (CAS #NDB000) 0 40 Phenol (CAS #108952) 0 4000 Styrene (CAS #100425) 0 200 Tetrachloroethylene (Perchloroethylene) (CAS #127184) 0 4000 Toluene (CAS #108883) 0 4000 Trichloroethylene (CAS #79016) 0 4000 Xylenes (Isomers And Mixture) (CAS #1330207) 0 4000 Change (TPY) Total (TPY) Total HAPs 0 45.27 Note: Change in emissions indicates the difference between previous AO and proposed modification. Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 4 Review of BACT for New/Modified Emission Units 1. BACT review regarding New Equipment New Electric Kiln The kiln will be used to vitrify ceramics by burning off organic matter in the ceramic and removing all water embedded in the atomic structure. The kiln is electric and will have ductwork designed to remove off-gassing products through a stack. The new electric kiln will emit VOC, NOx, PM2.5, PM10, CO, and HAPs emissions in negligible levels (<0.1 tpy, each). Therefore, additional controls to reduce emissions from the electric kiln are not cost-effective. BACT to control emissions from the electric kiln is best management practices, including proper maintenance and operation of the equipment. New Electric Oven The new electric oven will be used to cure a thermoset resin in order to make the product infusible, insoluble, and unable to return to its uncured state. There will be ductwork designed to remove off- gassing products through a stack. Less than 0.1 tpy of VOC and less than 0.01 tpy of HAPs will be emitted from the process. Therefore, additional controls to reduce emissions from the electric oven are not cost-effective. BACT to control emissions from the electric oven is best management practices, including proper maintenance and operation of the equipment. New Natural Gas-fired Oven (O-52) Northrop proposes to install one natural gas-fired oven (O-52) with a maximum rated capacity of 1.0 MMBtu/hr. The oven will be used to cure thermoset resin, similar to the new electric oven. The natural gas-fired oven will emit VOCs, PM2.5, PM10, SO2, and HAPs in negligible levels (<0.1 tpy, each). The oven will emit 0.42 tpy of NOx and 0.35 tpy of CO. Additional controls to reduce emissions from the electric oven are not cost effective. Therefore, BACT to control emissions from the electric oven is best management practices, including proper maintenance and operation of the equipment. New Spray Booth Northrop proposes to install one spray booth designed to remove overspray and vapors produced during paint spraying operation. The new spray booth will emit 1.2 tpy of VOCs and 0.13 tpy each of PM10 and PM2.5. Technologies to controls VOCs include a regenerative thermal oxidizer (RTO), a carbon adsorption system, and best management practices. RTOs are considered technically infeasible for the spray booth as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the flue gas. In a 2019 BACT analysis, Northrop found that a carbon adsorber for a spray booth with a PTE of 0.54 TPY had a cost effectiveness of $2.6 million/ton of VOC for canister replacement and $187,565/ton of VOC for carbon replacement. While the PTE of VOCs from the spray booth is double that of the study, the cost effectiveness still exceeds $1 million/ ton of VOC reduced. The DAQ does not consider this economically feasible. Therefore, BACT to control VOC emissions from the spray booth is best management practices. Technologies to control PM10/PM2.5 include electrostatic precipitators (ESP), fabric filters, and high-volume low-pressure (HVLP) spray guns. ESPs are considered technically infeasible for the spray booth as they are most effective on metals and items of high resistivity. Baghouses are dust collectors made of fabric filters that remove particulate matter via filtration. HVLP spray guns reduce PM emissions from paint application by increasing paint application efficiency. HVLP spray guns result in better coverage and less material loss. The use of a 3-stage fabric filter and HVLP spray guns are considered to be technically feasible. Therefore, BACT to control Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 5 PM10/PM2.5 emissions from the spray booths is use of a 3-stage fabric filter and HVLP spray guns. [Last updated January 24, 2024] 3. BACT review regarding New Equipment (Continued) New Receiving Exhaust Hood Northrop proposes to install a receiving hood above a platen press that will capture emissions resulting from peroxide-curing of rubber. VOC and HAPs emissions will be the only emissions exhausted through the receiving hood and are based on the mass of rubber cured per year. VOC and HAPs emissions will be less than 0.001 tpy, each. Therefore, additional add-on control technologies are not cost-effective. BACT is best management practices. In additional to the above BACT determinations, the source is subject to UAC R307-325 (Ozone Nonattainment and Maintenance Areas: General Requirements). These are general provisions that require sources in an ozone nonattainment area not to spill, discard, or store any VOC containing materials in any other manner that could results in greater VOC emissions. The source is also subject to UAC R307-355 (Control of Emissions from Aerospace Manufacture and Rework Facilities) as the facility is an aerospace manufacture and rework facility that has the potential to emit 10 tons or more per year of VOCs. The rule includes provisions for VOC content limits, application methods, work practices, and solvent cleaning. [Last updated January 24, 2024] 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 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] I.2 The limits set forth in this AO shall not be exceeded without prior approval. [R307-401] I.3 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.4 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] Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 6 I.5 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.6 The owner/operator shall comply with UAC R307-107. General Requirements: Breakdowns. [R307-107] I.7 The owner/operator shall comply with UAC R307-150 Series. Emission Inventories. [R307- 150] I.8 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] 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 Northrop Grumman Systems Corp Aerospace composite components manufacturing facility II.A.2 Six Electric Curing Ovens Ovens: O-21; O-36; O-48; O-159; O-160, IR&D Oven (New) II.A.3 NEW One IR&D Electric Kiln New Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 7 II.A.4 Twelve (12) Natural Gas-Fired Ovens Oven: Rating: O-26 1.2 MMBtu/hr O-27 4.0 MMBtu/hr COV1 2.8 MMBtu/hr COV2 4.0 MMBtu/hr O-30 3.5 MMBtu/hr O-22 2.0 MMBtu/hr O-24 0.6 MMBtu/hr O-37 3.0 MMBtu/hr O-39 6.4 MMBtu/hr O-41 1.0 MMBtu/hr O-47 3.0 MMBtu/hr O-52 1 MMBtu/hr (New) II.A.5 Six Hot Rooms Rooms: ACU253, AHU1, AHU2, AHU3, AHU4, HR1 Fuel: Natural Gas Maximum Rating: < 5.0 MMBtu/hr (each) II.A.6 One Boiler- BO1 Fuel: Natural Gas Rating: 8.37 MMBtu/hr II.A.7 Three Autoclaves Autoclave: Rating: AC1 12.0 MMBtu/hr AC6 24.3 MMBtu/hr AC12 15.0 MMBtu/hr Fuel: Natural Gas II.A.8 Five Autoclaves Autoclaves: CAC1, CAC2, CAC3, CAC4, CAC5 Fuel: Natural Gas Rating: 15.8 MMBtu/hr (each) II.A.9 Twelve Ventilation Rooms Ten Mandrel Prep Rooms; FX-141; Paint Touchup Room II.A.10 Ten Laboratory Hoods FUH-3; FUH-7; AT-401073; FUH-5; FUH-2; AT-401706; FE-200; FE-222; FUH-1; 2228 Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 8 II.A.11 Thirteen Exhaust Hoods 1,2. Two Welding fume exhausters 3. RMS-6 4. Battery Charging area exhaust hood 5. MX-85 6. M-5 7. 83310J00475 8. FX-105 9. FX-106 10. FE-655 11, 12. Two Paint mixing fume hoods 13. EPM Receiving (New) II.A.12 Four Heated Paint Booths Paint Booth: Heater Rating: SB10 750 KBtu/hr SB11 950 KBtu/hr SB12 950 KBtu/hr SB13 950 KBtu/hr Fuel: Natural Gas II.A.13 Seven Spray Booths SB7, SB9, SB5, SB14, IFE SB, Topcoat SB, SB (New) Control: Fabric Filters (each) II.A.14 One Ceramics Spray Booth Control: High efficiency 3-stage fabric filters II.A.15 One Thermal Spray Booth Control: Pulse jet baghouse (DC-58) Baghouse Maximum Flow Rate: 25,300 acfm MACT Applicability: Subpart WWWWWW Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 9 II.A.16 Eight Natural Gas-Fired Emergency Generators Engine: Rating: GE 3 7 kW GE 4 35 kW GE 5 100 kW GE 8 80 kW GE 9 240 kW NSPS Applicability: None MACT Applicability: Subpart ZZZZ Engine: Rating: GE 10 45 kW GE 11 45 kW GE 12 85 kW NSPS Applicability: Subpart JJJJ MACT Applicability: Subpart ZZZZ II.A.17 Two Diesel-Fired Emergency Generators Engine: GE 7 Rating: 225 kW Engine: GE 13 Rating: 268 hp NSPS Applicability: Subpart IIII MACT Applicability: Subpart ZZZZ II.A.18 Seven Dust Collectors DC-16, DC-27, DC-29, DC-30, DC-36, DC-37, DC-38 II.A.19 Miscellaneous Equipment Miscellaneous vacuum pumps Miscellaneous Air compressors II.A.20 Miscellaneous Combustion Equipment Various Boilers and Heaters Maximum Rating: <5.0 MMBtu/hr Fuel: Natural Gas II.A.21 Eighteen Wet Cooling Towers CT-6, CT-7, CT-9, CT-13, CT-14, CT-15, CT-16, CT-17, CT-18, CT-19, CT-20, CT-21, CT- 22, CT-23, CT-24, CT-25, CT-26, CT-27 Controls: High Efficiency Drift Eliminators (each) Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 10 II.A.22 Informational-Only Equipment* Nineteen electrical sample curing ovens One electrical Hot room Eight electrical autoclaves One Buffer room Miscellaneous Dust Collectors, including portable and orifice scrubbers Miscellaneous Machining Centers / Lathes / Cork Cutting Equipment One Spray Gun Cleaning Station Miscellaneous Grit Blast and Abrading Equipment 3D Printers *This equipment vents internally and is listed for informational purposes only II.A.23 Informational-Only Equipment* (Continued) Three Hot Drape Forming Machines One Ductless Fume Hood Two Reticulators Two Dry Cooling Towers *This equipment vents internally and is listed for informational purposes only II.A.24 Grandfathered Equipment* Pit exhaust system Indirect gas fired curing oven - #20 Rating: 6 MMBtu/hr *This equipment was installed before 1969 and is listed for informational purposes only 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 Site-Wide 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 engines - 20% opacity B. All other emission points - 10% opacity [R307-401-8] II.B.1.a.1 Opacity observations of emissions from stationary sources shall be conducted according to 40 CFR 60, Appendix A, Method 9. [R307-401-8] Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 11 II.B.1.b The owner/operator shall not exceed a plant-wide natural gas consumption limit of 406,624 Decatherms per rolling 12-month period. [R307-401-8] II.B.1.b.1 The owner/operator shall: A. Determine consumption by gas billing records B. Record consumption on a monthly basis C. Use the consumption records to calculate a new rolling 12-month total by the 20th day of each month using data from the previous 12 months D. Keep consumption records for all periods the plant is in operation. [R307-401-8] II.B.1.c The owner/operator shall comply with all applicable requirements of UAC R307-325 (Ozone Nonattainment and Maintenance Areas: General Requirements) and UAC R307-355 (Control of Emissions from Aerospace Manufacture and Rework Facilities), [R307-355] II.B.2 VOC & HAP Requirements Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 12 II.B.2.a NEW The owner/operator shall not emit more than the following from all sources on site: A. 69.00 tons per rolling 12-month period of VOCs B. 19.00 tons per rolling 12-month period of all HAPs combined C. 2.00 tons per rolling 12-month period of 2-Butoxyethanol D. 0.014 tons per rolling 12-month period of Chromium Compounds E. 2.00 tons per rolling 12-month period of Cumene F. 2.00 tons per rolling 12-month period of Ethyl Acrylate G. 2.00 tons per rolling 12-month period of Ethylbenzene H. 2.00 tons per rolling 12-month period of Ethylene Glycol I. 0.50 tons per rolling 12-month period of Formaldehyde J. 2.00 tons per rolling 12-month period of Glycol Ethers K. 0.007 tons per rolling 12-month period of Hexamethylene-1,6-Diisocyanate L. 2.00 tons per rolling 12-month period of Hexane M. 0.010 tons per rolling 12-month period of Hydrogen Fluoride M. 2.00 tons per rolling 12-month period of Methyl Alcohol O. 0.010 tons per rolling 12-month period of Methyl Isocyanate P. 2.00 tons per rolling 12-month period of Methylene Chloride Q. 0.10 tons per rolling 12-month period of Methylenedianiline R. 0.010 tons per rolling 12-month period of Methylene Diphenyl Diisocyanate S. 2.00 tons per rolling 12-month period of Methyl Isobutyl Ketone (MIBK) T. 2.00 tons per rolling 12-month period of Naphthalene Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 13 II.B.2.a NEW The owner/operator shall not emit more than the following from all sources on site continued: U. 0.02 tons per rolling 12-month period of Nickel Compounds V. 2.00 tons per rolling 12-month period of Phenol W. 2.00 tons per rolling 12-month period of Tetrachloroethylene X. 2.00 tons per rolling 12-month period of Toluene Y. 9.50 tons per rolling 12-month period of 1,1,1-Trichloroethane Z. 2.00 tons per rolling 12-month period of 1,1,2-Trichloroethane AA. 2.00 tons per rolling 12-month period of Trichloroethylene BB. 2.00 tons per rolling 12-month period of Xylene CC. 1.20 tons per rolling 12-month period of all other HAPs [R307-401-8] II.B.2.a.1 NEW The owner/operator shall calculate a new 12-month total by the 20th day of each month using data from the previous 12 months. The owner/operator shall use a mass-balance method to calculate emissions from evaporative sources. The owner/operator may use the following equations with applicable units to comply with the mass-balance method: VOCs = [% VOCs by Weight/100] x [Density] x [Volume Consumed] Non-Metal HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] Metal HAP = [% HAP by Weight/100] x [Density] x [Volume Consumed] x [filter control efficiency] [R307-401-8] II.B.2.a.2 The owner/operator shall use a mass-balance method to quantify any amount of VOCs and HAPs reclaimed. The owner/operator shall subtract the amount of VOCs and HAPs reclaimed from the quantities calculated above to provide the monthly total emissions of VOCs and HAPs. [R307-401-8] Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 14 II.B.2.a.3 The owner/operator shall keep records each month of the following: A. The name (as per SDS) of the VOC- and HAP-emitting material B. The maximum percent by weight of VOCs and each HAP in each material used C. The density of each material used D. The volume of each VOC- and HAP-emitting material used E. The amount of VOCs and the amount of each HAP emitted from each material F. The amount of VOCs and the amount of each HAP reclaimed and/or controlled from each material G. The total amount of VOCs, the total amount of each HAP, and the total amount of all HAPs combined emitted from all materials (in tons) [R307-401-8] II.B.3 Paint Booth Requirements II.B.3.a The owner/operator shall equip each paint booth with paint arrestor particulate filters to control particulate emissions. All exhaust air from the paint booths shall be routed through the filters before venting to the atmosphere. [R307-401-8] II.B.3.b The paint booths shall be equipped with HVLP spray guns, or an equivalent method, to control VOC emissions. [R307-355-6] II.B.3.c The owner/operator shall control the thermal spray booth with a baghouse. [R307-401-8] II.B.3.d NEW The owner/operator shall install a manometer or magnehelic pressure gauge to measure the differential pressure across the thermal spray booth baghouse. The baghouse shall operate within the static pressure range recommended by the manufacturer for normal operations. [R307-401-8] II.B.3.d.1 Pressure drop readings shall be recorded at least once during each day of operation while the baghouse is operating. Records documenting the pressure drop shall be kept in a log and shall include the following: A. Unit identification B. Manufacturer-recommended pressure drop for the unit C. Daily pressure drop readings D. Date of reading [R307-401-8] II.B.3.d.2 NEW The pressure gauge shall be located such that an inspector/operator can safely read the indicator at any time. [R307-401-8] Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 15 II.B.3.d.3 The instrument shall be calibrated in accordance with the manufacturer's instructions or recommendations or replaced at least once every 12 months. Documentation of calibrations and replacements shall be maintained. [R307-401-8] II.B.4 Emergency Engine Requirements II.B.4.a The owner/operator shall not operate each emergency engine on site for more than 100 hours per calendar year during non-emergency situations. There is no time limit on the use of the engines during emergencies. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.a.1 To determine compliance with a calendar year total, the owner/operator shall calculate a new yearly total by January 31st using data from the previous calendar 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 [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.4.a.2 To determine the duration of operation, the owner/operator shall install a non-resettable hour meter for each emergency engine. [40 CFR 63 Subpart ZZZZ, R307-401-8] II.B.5 Fuel Requirements II.B.5.a The owner/operator shall use only natural gas as a fuel in all fuel-burning furnaces, ovens, boilers, heaters, and natural gas-fired emergency engines. [R307-401-8] II.B.5.b The owner/operator shall only use diesel fuel (fuel oil #1, #2 or diesel fuel oil additives) in the diesel-fired emergency engines. All diesel burned shall meet the definition of ultra-low sulfur diesel (ULSD) and contain no more than 15 ppm sulfur. [R307-401-8] II.B.5.b.1 To demonstrate compliance with the diesel fuel requirements for any diesel fuel purchased, the owner/operator shall keep and maintain fuel purchase invoices. The fuel purchase invoices shall indicate that the diesel fuel meets the ULSD requirements, or the owner/operator shall obtain certification of sulfur content from the fuel supplier. [R307-401-8] Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 16 PERMIT HISTORY When issued, the approval order shall supersede (if a modification) or will be based on the following documents: Is Derived From NOI dated December 15, 2023 Supersedes AO DAQE-AN101520030-24 dated January 18, 2024 REVIEWER COMMENTS 1. Comment regarding HAP Emissions: Condition II.B.2.a contains a 19.00 TPY rolling 12-month limit for all HAPs combined. Additionally, Condition II.B.2.a also includes individual HAP limits. If added up, these individual limits exceed the total HAP limit. Northrop has been given individual limits to add greater flexibility in their operations, with an established combined HAP limit which prevents Northrop from becoming a major source of HAP emissions. The generic HAP limit was established to provide Northrop flexibility in their operations for when minor processes use HAPs other than those listed. As requested by Northrop, total VOC and HAP emission limitations will not be changing with this modification. [Last updated December 20, 2023] 2. Comment regarding Modification: In additional to the one (1) electric kiln, one (1) electric oven, one (1) natural gas-fired oven, one (1) spray booth, and one (1) receiving hood exhaust installation request, Northrop has proposed the removal of the HR-3 hot room, the SB-2 laboratory hood, the E-145 exhaust hood, and the DC-28 dust collector due to decommissioning. The Equipment IDs are II.A.4, II.A.9, II.A.10, and II.A.17 (respectively) in AO DAQE-AN101520030-24. Removing the HR-3 hot room results in an emissions decrease of 0.0020 tpy of VOCs, 0.036 tpy of NOx, 0.0027 tpy each of PM10 and PM2.5, 0.030 tpy of CO, and less than 0.001 tpy of HAPs. The removal of the D-28 dust collector. results in an emissions decrease of 0.42 tpy each of PM10 and PM2.5. The reduction in emissions from the removal of the SB-2 laboratory hood and E-145 exhaust hood were not quantified as Northrop is not proposing a limit change for VOC/HAPs. [Last updated January 12, 2024] 3. Comment regarding Source Emission Calculations and DAQ Acceptance: Added Equipment Electric Kiln PM emission factors from AP-42 Chapter 11.7, Table 11.7-1. All other emission factors are from AP-42 Chapter 11.7, Table 11.7-2 Electric Oven HAP and VOC off-gas emissions rates were determined from on-site sample data. A 15-minute sample was taken from the exhaust stream of an oven when the oven reached the maximum cure temperature. Emission rates are calculated based on the pollutant concentration and the maximum rated flow rate of the oven fan (310 acfm). Annual emissions are conservatively based on continuous operation for 8,760 hours per year (hr/yr). Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 17 Natural Gas-Fired Oven Emission factors are from AP-42, Section 1.4 Natural Gas Combustion for an uncontrolled boiler <100 MMBtu/hr. Hourly emissions are based on operation of the 1 MMBtu/hr natural gas-fired oven at full capacity and assuming a fuel heat content of 1044 Btu/scf. Annual emissions were calculated assuming 8760 hrs/yr of operation. Spray Booth Emissions of VOCs and HAPs are calculated using the VOC or HAP content (volume percent), the density, and the expected gallons of the respective paint used per year. Emissions are conservatively based on all VOC and HAP being emitted via the stack. Controlled PM emissions account for the control efficiency of the HVLP spray gun (65%) and the fabric filter efficiency (97.5%). Annual emissions were calculated assuming 8760 hrs/yr of operation and maximum paint usage. Receiving Hood Exhaust The receiving hood exhaust emissions are estimated using emissions factors for VOC and HAPs from Section 4.12 of the EPA's AP-42 emission factor document. Emissions are calculated based on a maximum of 11 shipsets per year, assuming 913 feet (ft) of rubber per set, at a mass of 167 lb rubber per 300 ft roll (5,591 lb rubber per year). Removed Equipment H-3 Hot Room Emission factors are from AP-42 Section 1.4: Natural Gas Combustion. Table 1.4-1, and 1.4-2. Emissions are based on operation of the 0.084 MMBtu/hr burner at full capacity. Annual emissions were calculated assuming 8760 hrs/yr of operation. DC-28 Dust Collector Emissions are based on operation of the 702 scfm baghouse at full capacity. Annual emissions were calculated assuming 8,760 hrs/yr of operation. A grain loading rate of 0.016 gr/scf was used, as listed in Northrops 2022 emissions inventory. [Last updated December 21, 2023] 4. Comment regarding NSPS and MACT Applicability: 40 CFR 60 NSPS Subpart IIII - Standards of Performance or Stationary Compression Ignition Internal Combustion Engines The provisions of this subpart apply to owners and operators of stationary CI ICE that commence construction after July 11, 2005, where the stationary CI ICE are manufactured after April 1, 2006. The two (2) diesel-fired emergency stationary engines at this facility were constructed after this date and are therefore subject to NSPS Subpart IIII. 40 CFR 60 NSPS Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines The provisions of this subpart apply to owners and operators of stationary SI ICE that commence construction after June 12, 2006, where the stationary SI ICE are manufactured on or after July 1, 2008, for engines with a maximum engine power less than 500 HP. The eight (8) natural gas-fired emergency stationary engines on site were constructed after this data and are therefore subject to NSPS Subpart JJJJ. 40 CFR 63 Subpart ZZZZ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines The provisions of this subpart are applicable to owners/operators of stationary RICE at a major or area sources of HAP emissions. The facility includes (2) diesel-fired emergency stationary engines and eight (8) natural gas-fired emergency stationary engines. The provisions of MACT Subpart Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 18 ZZZZ apply as the stationary reciprocating internal combustion engine (RICE) is at an area source of HAP emissions. The engines are not designated as nonroad and are not exempt are affected sources under this regulation. Therefore, MACT Subpart ZZZZ applies to this facility. 40 CFR 63 Subpart WWWWWW - National Emissions Standards for Hazardous Air Pollutants: Area Source Standards for Plating and Polishing Operations This subpart applies to owners and operators of affected sources at plating and polishing facilities that are area sources of HAPs. This subpart specifically applies to plating and polishing facilities that use one or more plating and polishing metal HAPs, including compounds of nickel, in affected sources, including thermal spraying. This source is considered an area source of HAPs and has a thermal spraying operation using nickel compounds; therefore, MACT Subpart WWWWWW applies to this source. MACT Subpart WWWWWW contains capture system requirements for thermal spraying operations. Northrop has chosen to comply with the capture system requirements with a pulse jet baghouse to control the thermal spraying operations. In addition to this requirement, MACT Subpart WWWWWW contains other management practices, equipment and operating standards, and notification, reporting, and recordkeeping requirements for thermal spraying operations. [Last updated December 21, 2023] 5. Comment regarding Title V Applicability: Title V of the 1990 CAA (Title V) applies to the following: A. Any major source B. Any source subject to a standard, limitation, or other requirement under Section 111 of the Act, Standards of Performance for New Stationary Sources C. Any source subject to a standard or other requirement under Section 112 of the Act, Hazardous Air Pollutants D. Any Title IV-affected source This facility is not a major source and is not a Title IV source, but is subject to 40 CFR 60 NSPS Subparts A, IIII, and JJJJ, and 40 CFR 63 MACT Subparts A, ZZZZ, and WWWWWW regulations. However, Title V does not apply because NSPS Subparts IIII and JJJJ and MACT Subparts ZZZZ and WWWWWW exempt sources from the obligation to obtain a permit under 40 CFR part 70 (Title V permit) if the source is not otherwise required by law to obtain a permit. There are no other reasons why this source would be required to obtain a part 70 permit; therefore, Title V does not apply to this facility. [Last updated December 21, 2023] Engineer Review N101520031: Northrop Grumman Systems Corp. - Clearfield Freeport Center January 24, 2024 Page 19 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 Electric Kiln (addition) Pollutant EF (lb/ton)tpy lb/hrNOX0.54 0.0030222 0.00069 CO 3.3 0.018469 0.0042167PM10 /PM2.5 0.49 0.00274237 0.0006261 SO2 NA 0 0 VOC 0.43 0.00240657 0.0005494 184 lb ceraminc parts/run 3 days/run 22386.66667 lbs/yr ceramic 2.5555556 lbs/hr ceramic 11.19333333 tpy ceramin 0.0012778 tons/hr ceramic Hot Room (0.084 MMBtu/hr boiler) (Removed)Dust Colle Pollutant EF (lbs/hr)(tons/year)Pollutant NOX 100 0.01 0.04 PM10 CO 84 0.01 0.03 PM2.5 PM10 7.6 0.00 0.00 PM2.5 7.6 0.00 0.00 SO2 0.6 0.00 0.00 VOC 5.5 0.00 0.00 Lead 0.0005 0.00 0.00 HAP 0.00 0.00 Current AO Changes New PTE For 5 NOI CO 16.38 0.35 16.73 16.72 NOx 19.49 0.40 19.89 19.88 PM10 13.42 -0.26 13.16 13.03 PM2.5 13.21 -0.26 12.95 12.95 SO2 0.15 0.00 0.15 0.15 VOC 69 0.04238 69.04 69 HAPs 45.27 0.54890 45.82 19 NGSC is looking to add an electric kiln, an electric oven, a natural gas-fired oven (1 MMBtu/hr), a spr hood, an exhaust hood, and a dust collector. The laboratory and exhaust hood emission Electric Oven (addition)O-52 NG Boile Pollutant EF (ug/m3)tpy lb/hr Pollutant Dichlorodif 2.6 VOC 1.32E-05 3.02E-06 NOX Chloromet 1.8 VOC HAP 9.15E-06 2.09E-06 CO Acetone 250 VOC 1.27E-03 2.90E-04 PM10 2-Butanon 17 VOC 8.65E-05 1.97E-05 PM2.5 Ethanol 339 VOC 1.72E-03 3.94E-04 SO2 Isopropyl A 1,991 VOC 1.01E-02 2.31E-03 VOC Heptane 2.8 VOC 1.42E-05 3.25E-06 Lead 4-Methyl-2 4.2 VOC 2.14E-05 4.88E-06 HAP Toluene 12 VOC HAP 6.10E-05 1.39E-05 2-Pentano 23 VOC 1.17E-04 2.67E-05 VOC total 0.01344 0.00307 310 ft3/min HAP total 0.00007 0.00002 8.778218 m3/min ector (Removed) EF gr/scf (lbs/hr)(tons/year) 0.016 0.10 0.42 0.016 0.10 0.42 702 scfm 8760 hour/yr Difference -0.01 -0.01 -0.13 All < 0.25 tpy 0.00 0.00 -0.04 ray booth, and a receiving hood exhaust to its permit. The Facility will remove a hot room, a laboratory n reductions were not quantified as VOC and HAP limits are proposed to stay the same. er (1MMBtu/hr) (addition)Spray Booth (addition) EF (lbs/hr)(tons/year) 100 0.10 0.43 Pollutant tpy lb/hr 84 0.08 0.36 VOCs 1.2 0.273972603 7.6 0.01 0.03 PM 0.13 0.029680365 7.6 0.01 0.03 Methyl Isobu 0.1 0.02283105 0.6 0.00 0.00 Formaldehyd 0.04 0.00913242 5.5 0.01 0.02 Hexamethyle 0.4 0.091324201 0.0005 0.00 0.00 0.00 0.01 HAP total 0.54 0.123287671 *HVLP nozzel - 65% *fabric filter - 97.5% pm10 pm2.5 -0.388 -0.258 -0.26 -0.26 Hood (addition) Pollutant tpy lb/hr VOC total 0.00490 9.80000 HAP total 0.00140 2.80000 Heating Value of Natural Gas 1020 BTU/scf or MMBtu/MMscf Equipment Details Rating 0 MMBtu/hour NOx Size Table 1.4-1 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check Operational Hours 8,760 hours/year >100 MMBtu/hr Uncontrolled - Pre NSPS (Subparts D & Db)280 0.2745 0.02 0.10 Firing Normal >100 MMBtu/hr Uncontrolled - Post NSPS (Subparts D & Db)190 0.1863 0.02 0.07 >100 MMBtu/hr Controlled - Low Nox burners 140 0.1373 0.01 0.05 Criteria Pollutant Concentration (ppm) Emission Factor (lb/10^6 scf) Emission Rate (lbs/hr) Emission Total (tons/year)Reference >100 MMBtu/hr Controlled - Flue gas recirculation (FGR)100 0.0980 0.01 0.04 Match NOX 100 0.01 0.04 <100 MMBtu/hr Uncontrolled 100 0.0980 0.01 0.04 Match CO 84 0.01 0.03 <100 MMBtu/hr Controlled - Low Nox burners 50 0.0490 0.00 0.02 PM10 7.6 0.00 0.00 <100 MMBtu/hr Controlled - Low Nox burners/FGR 32 0.0314 0.00 0.01 PM2.5 7.6 0.00 0.00 Tangential-Fired Uncontrolled 170 0.1667 0.01 0.06 SO2 0.6 0.00 0.00 Tangential-Fired Controlled - FGR 76 0.0745 0.01 0.03 VOC 5.5 0.00 0.00 Lead 0.0005 0.00 0.00 CO Size Table 1.4-1 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check HAP 0.00 0.00 See Below >100 MMBtu/hr Uncontrolled - Pre NSPS (Subparts D & Db)84 0.0824 0.01 0.03 Match >100 MMBtu/hr Uncontrolled - Post NSPS (Subparts D & Db)84 0.0824 0.01 0.03 Match Green House Gas Pollutant Global Warming Potential Emission Factor (lb/10^6 scf) Emission Rate (lbs/hr) Emission Total (tons/year)Reference >100 MMBtu/hr Controlled - Low Nox burners 84 0.0824 0.01 0.03 MatchCO2 (mass basis)1 120,000 10 43 >100 MMBtu/hr Controlled - Flue gas recirculation (FGR)84 0.0824 0.01 0.03 Match Methane (mass basis)25 2.3 0.00 0.00 <100 MMBtu/hr Uncontrolled 84 0.0824 0.01 0.03 MatchN2O (mass basis)298 2.2 0.00 0.00 <100 MMBtu/hr Controlled - Low Nox burners 84 0.0824 0.01 0.03 Match CO2e 44 <100 MMBtu/hr Controlled - Low Nox burners/FGR 84 0.0824 0.01 0.03 Match Tangential-Fired Uncontrolled 24 0.0235 0.00 0.01 Hazardous Air Pollutant Emission Rate (lbs/hr) Emission Total (tons/year)Reference Tangential-Fired Controlled - FGR 98 0.0961 0.01 0.04 2-Methylnaphthalene 2.40E-05 1.98E-09 8.66E-09 3-Methylchloranthrene 1.80E-06 1.48E-10 6.49E-10 Any Size Table 1.4-2 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check 7,12-Dimethylbenz(a)anthracene 1.60E-05 1.32E-09 5.77E-09 CO2 120,000 117.6471 10 43 Match Acenaphthene 1.80E-06 1.48E-10 6.49E-10 Lead 0.0005 0.0000 0.00 0.00 Match Acenaphthylene 1.80E-06 1.48E-10 6.49E-10 N2O Uncontrolled 2.2 0.0022 0.00 0.00 Match Anthracene 2.40E-06 1.98E-10 8.66E-10 Controlled - Low Nox burners 0.64 0.0006 0.00 0.00 Benz(a)anthracene 1.80E-06 1.48E-10 6.49E-10 PM (total)7.6 0.0075 0.00 0.00 Match Benzene 2.10E-03 1.73E-07 7.57E-07 PM (cond)5.7 0.0056 0.00 0.00 Benzo(a)pyrene 1.20E-06 9.88E-11 4.33E-10 PM (filter)1.9 0.0019 0.00 0.00 Benzo(b)fluoranthene 1.80E-06 1.48E-10 6.49E-10 SO2 0.6 0.0006 0.00 0.00 Match Benzo(g,h,i)perylene 1.20E-06 9.88E-11 4.33E-10 TOC 11 0.0108 0.00 0.00 Benzo(k)fluoranthene 1.80E-06 1.48E-10 6.49E-10 Methane 2.3 0.0023 0.00 0.00 Match Chrysene 1.80E-06 1.48E-10 6.49E-10 VOC 5.5 0.0054 0.00 0.00 Match Dibenzo(a,h)anthracene 1.20E-06 9.88E-11 4.33E-10 Dichlorobenzene 1.20E-03 9.88E-08 4.33E-07 Global Warming Potential lb/hr Ton/year Fluoranthene 3.00E-06 2.47E-10 1.08E-09 CO2 1 10 43 Fluorene 2.80E-06 2.31E-10 1.01E-09 Methane 25 0 0 Formaldehyde 7.50E-02 6.18E-06 2.71E-05 N2O 298 0 0 Hexane 1.80E+00 1.48E-04 6.49E-04 CO2e Total CO2e 10 44 Match Indeno(1,2,3-cd)pyrene 1.80E-06 1.48E-10 6.49E-10 Naphthalene 6.10E-04 5.02E-08 2.20E-07 HAP - Organic Table 1.4-3 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check Phenanathrene 1.70E-05 1.40E-09 6.13E-09 2-Methylnaphthalene 2.40E-05 2.35E-08 1.98E-09 8.66E-09 Match Pyrene 5.00E-06 4.12E-10 1.80E-09 3-Methylchloranthrene 1.80E-06 1.76E-09 1.48E-10 6.49E-10 Match Toluene 3.40E-03 2.80E-07 1.23E-06 7,12-Dimethylbenz(a)anthracene 1.60E-05 1.57E-08 1.32E-09 5.77E-09 Match Arsenic 2.00E-04 1.65E-08 7.21E-08 Acenaphthene 1.80E-06 1.76E-09 1.48E-10 6.49E-10 Match Beryllium 1.20E-05 9.88E-10 4.33E-09 Acenaphthylene 1.80E-06 1.76E-09 1.48E-10 6.49E-10 Match Cadmium 1.10E-03 9.06E-08 3.97E-07 Anthracene 2.40E-06 2.35E-09 1.98E-10 8.66E-10 Match Chromium 1.40E-03 1.15E-07 5.05E-07 Benz(a)anthracene 1.80E-06 1.76E-09 1.48E-10 6.49E-10 Match Cobalt 8.40E-05 6.92E-09 3.03E-08 Benzene 2.10E-03 2.06E-06 1.73E-07 7.57E-07 Match Manganese 3.80E-04 3.13E-08 1.37E-07 Benzo(a)pyrene 1.20E-06 1.18E-09 9.88E-11 4.33E-10 Match Mercury 2.60E-04 2.14E-08 9.38E-08 Benzo(b)fluoranthene 1.80E-06 1.76E-09 1.48E-10 6.49E-10 Match Nickel 2.10E-03 1.73E-07 7.57E-07 Benzo(g,h,i)perylene 1.20E-06 1.18E-09 9.88E-11 4.33E-10 Match Selenium 2.40E-05 1.98E-09 8.66E-09 Benzo(k)fluoranthene 1.80E-06 1.76E-09 1.48E-10 6.49E-10 Match Chrysene 1.80E-06 1.76E-09 1.48E-10 6.49E-10 Match Dibenzo(a,h)anthracene 1.20E-06 1.18E-09 9.88E-11 4.33E-10 Match Dichlorobenzene 1.20E-03 1.18E-06 9.88E-08 4.33E-07 Match Fluoranthene 3.00E-06 2.94E-09 2.47E-10 1.08E-09 Match Fluorene 2.80E-06 2.75E-09 2.31E-10 1.01E-09 Match Formaldehyde 7.50E-02 7.35E-05 6.18E-06 2.71E-05 Match Hexane 1.80E+00 1.76E-03 1.48E-04 6.49E-04 Match Indeno(1,2,3-cd)pyrene 1.80E-06 1.76E-09 1.48E-10 6.49E-10 Match Naphthalene 6.10E-04 5.98E-07 5.02E-08 2.20E-07 Match Phenanathrene 1.70E-05 1.67E-08 1.40E-09 6.13E-09 Match Pyrene 5.00E-06 4.90E-09 4.12E-10 1.80E-09 Match Toluene 3.40E-03 3.33E-06 2.80E-07 1.23E-06 Match HAP - Metal Table 1.4-4 lb/10^6 scf lb/MMBtu lb/hr Ton/year Check Arsenic 2.00E-04 1.96E-07 1.65E-08 7.21E-08 Match Beryllium 1.20E-05 1.18E-08 9.88E-10 4.33E-09 Match Cadmium 1.10E-03 1.08E-06 9.06E-08 3.97E-07 Match Chromium 1.40E-03 1.37E-06 1.15E-07 5.05E-07 Match Cobalt 8.40E-05 8.24E-08 6.92E-09 3.03E-08 Match Manganese 3.80E-04 3.73E-07 3.13E-08 1.37E-07 Match Mercury 2.60E-04 2.55E-07 2.14E-08 9.38E-08 Match Nickel 2.10E-03 2.06E-06 1.73E-07 7.57E-07 Match Selenium 2.40E-05 2.35E-08 1.98E-09 8.66E-09 Match Total HAP Total HAP lb/hr Ton/year Check 0.00 0.00 Match ppm to lb/MMBtu Conversion. Source: AQMD Permit Sample Evaluation Natural Gas Fired Boiler 5-20 MMBTU/HR, 2007 Nox Molecular Weight 46.1 lb/lb-mole CO Molecular Weight 28.01 lb/lb-mole Concentration lb/MMBtu lb/hr Ton/year Check Nox 0 0 0.00 0.00 CO 0 0 0.00 0.00 AP-42 Table 1.4-3 AP-42 Table 1.4-4 Natural Gas-Fired Boilers & Heaters Manufacturer Data or AP-42 Table 1.4-1 AP-42 Table 1.4-2 AP-42 Table 1.4-2 & Table A-1 to Subpart A of Part 98 Emission Factor (lb/10^6 scf) Page 5 of Version 1.0 November 29, 2018 Prepared for Northrop Grumman Systems Corp. Freeport Center 14th Street Clearfield, Utah Prepared by Ramboll Americas Engineering Solutions Salt Lake City, Utah Project Number 1940104540 Date December 2023 NORTHROP GRUMMAN SYSTEMS CORP. CLEARFIELD FACILITY NOTICE OF INTENT UTAH DIVISION OF AIR QUALITY CLEARFIELD, UTAH Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Contents 1 Ramboll CONTENTS 1. 1 2. 2 3. 3 3.1 3 3.2 3 3.3 4 3.4 4 3.5 4 3.6 4 3.7 5 4. 7 4.1 7 4.2 7 4.3 7 4.4 7 4.5 8 4.5.1 8 4.5.2 8 5. 9 5.1 9 5.1.1 10 5.1.2 11 5.2 12 5.2.1 12 5.2.2 12 5.2.3 12 5.2.4 12 5.2.5 12 5.3 12 5.3.1 12 5.3.2 12 5.3.3 12 5.3.4 13 5.3.5 13 5.4 13 5.4.1 13 5.4.2 13 5.4.3 13 5.4.4 13 5.4.5 13 5.5 13 5.5.1 13 5.5.2 14 5.5.3 14 5.5.4 14 5.5.5 14 5.6 14 5.6.1 14 5.6.2 15 5.6.3 15 Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Contents 2 Ramboll 5.6.4 15 5.6.5 15 5.7 15 5.7.1 15 5.7.2 16 5.7.3 16 5.7.4 16 5.7.5 17 5.8 17 5.8.1 17 5.8.2 17 5.8.3 17 5.8.4 17 5.8.5 17 5.9 17 5.9.1 17 5.9.2 18 5.9.3 18 5.9.4 18 5.9.5 18 5.10 18 5.10.1 18 5.10.2 19 5.10.3 19 5.10.4 19 5.10.5 19 5.11 19 5.11.1 19 5.11.2 19 5.11.3 19 5.11.4 20 5.11.5 20 5.12 20 5.12.1 20 5.12.2 20 5.12.3 20 5.12.4 21 5.12.5 21 5.13 21 5.13.1 21 5.13.2 21 5.13.3 21 5.13.4 22 5.13.5 22 5.14 22 5.14.1 22 5.14.2 22 5.14.3 22 5.14.4 22 5.14.5 22 Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Contents 3 Ramboll TABLES Table 1: Maximum Annual Controlled Facility Emissions APPENDICES Appendix A: Facility Maps and Diagrams Appendix B: UDAQ NOI Forms Appendix C: Potential Emissions Calculations Appendix D: Detailed Process Flow Diagrams Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Contents 4 Ramboll ACRONYMS AND ABBREVIATIONS °C degrees Celsius °F degrees Fahrenheit acfm Actual Cubic Feet per Minute AP-42 Compilation of Air Pollutant Emission Factors AO Approval Order BACT Best Available Control Technology cfm Cubic feet per minute CFR Code of Federal Regulations CO Carbon Monoxide CO2 Carbon Dioxide CO2e Carbon Dioxide Equivalent EPA Environmental Protection Agency ESP Electrostatic Precipitator FGR Flue Gas Recirculation ft3 Cubic Feet g Gram GCP Good Combustion Practices GHGs Greenhouse Gases GMP Good management practices HAPs Hazardous Air Pollutants HVLP High-Volume, Low-Pressure IR&D Independent Research and Development LNB Low-NOx Burner µm Micrometer MMBtu/hr Million British Thermal Unit Per Hour MT/y Megatons per Year NAAQS National Ambient Air Quality Standards NESHAP National Emission Standards for Hazardous Air Pollutants NGSC Northrop Grumman Systems Corporation NH3 Ammonia NNSR Nonattainment New Source Review NOI Notice of Intent NOX Nitrogen Oxides (NO + NO2) NSPS New Source Performance Standards Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Contents 5 Ramboll NSR New Source Review O3 Ozone PM Particulate Matter PM2.5 Particulate Matter Less Than 2.5 Micrometers in Aerodynamic Diameter PM10 Particulate Matter Less Than 10 Micrometers in Aerodynamic Diameter ppmv Parts Per Million by Volume PSD Prevention of Significant Deterioration PTE Potential To Emit RBLC RACT/BACT/LAER Clearinghouse RTO Regenerative Thermal Oxidizer SCR Selective Catalytic Reduction SO2 Sulfur Dioxide TPY Tons Per Year UAC Utah Administrative Code UDAQ Utah Department of Air Quality ULNB Ultra Low-NOx Burner VOC Volatile Organic Compounds Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Introduction 1 Ramboll 1. INTRODUCTION The Northrop Grumman Systems Corp. (NGSC) owns and operates an aerospace structures manufacturing facility (referred to as “Facility”) located at Freeport Center 14th Street, Clearfield, Utah. The general operations include raw material receipt and storage, material and tool preparation, fabrication, curing, finishing, testing, packing, and shipping. Facility operation is currently authorized by Utah Department of Environmental Quality – Division of Air Quality (UDAQ) Approval Order DAQE-AN101520028-22 (AO), most recently issued on September 26, 2022. The Facility is classified as a minor source of air emissions under both the Title V and federal New Source Review (NSR) permitting programs. NGSC is submitting this Notice of Intent (NOI) to UDAQ to request approval to install an electric kiln (Independent Research & Development (IR&D) Kiln), an electric oven (IR&D Oven), a natural gas-fired oven (O-52), a spray booth, and a receiving hood exhaust. NGSC also proposes to remove the following equipment from their AO due to decommissioning: the HR-3 hot room, the SB-2 laboratory hood, the E-145 exhaust hood, and the DC-28 dust collector. NGSC would also like to change the identification of two pieces of equipment. A site map with the location of equipment added to the Facility is provided in Appendix A. NGSC is not proposing to modify its existing facility-wide volatile orgNewanic compound (VOC) and hazardous air pollutant (HAP) emission limits. The presented VOC and HAP emissions from added equipment will be folded into its existing 69.00 tons per year (TPY) VOC and 19.00 TPY HAP limits in the current AO. Therefore, in accordance with under R307-403-1, NGSC will remain under the VOC major source threshold of 70 TPY for facilities located within the nonattainment area for particulate matter with a diameter of 2.5 microns (PM2.5) or less.1 NGSC is submitting this NOI to request an AO in accordance with the requirements of the Utah Administrative Code (UAC) Rule R307-401-5.2 The NOI application forms are included in Appendix B of this report. 1 Utah Admin. Code R307-403-1. https://adminrules.utah.gov/public/rule/R307-403/Current%20Rules 2 Utah Admin. Code R307-401-5. https://rules.utah.gov/publicat/code/r307/r307-401.htm#T8 Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Process Description 2 Ramboll 2. PROCESS DESCRIPTION To support manufacturing processes, NGSC currently operates natural gas-fired ovens, hot rooms, autoclaves, paint booths, boilers, and heaters; ventilation rooms, laboratory hoods, and exhaust hoods to vent various processes; electric curing ovens; dust collectors for control of various machining processes; painting and welding activities; and wet cooling towers with high efficiency drift eliminators. Approval Order Additions: NGSC proposes to install one (1) electric kiln, one (1) electric oven, one (1) natural gas-fired oven, one (1) spray booth, and one (1) receiving hood exhaust at the Facility. The IR&D Kiln is an electric kiln with a capacity of 99 cubic feet (ft3). The IR&D Oven is an electric oven with an exhaust rate of 310 actual cubic feet per minute (acfm). The O-52 oven is a natural gas-fired oven with a firing rate of 1.0 million British thermal units per hour (MMBtu/hr). The spray booth will be installed with a high volume low pressure (HVLP) spray gun and vented using a vacuum flow rate of 1,462 acfm through a high flow filtration system. Emissions from the Receiving Hood Exhaust are based on the mass of rubber cured per year. Approval Order Changes: NGSC proposes to remove of the HR-3 hot room, the SB-2 laboratory hood, the E-145 exhaust hood, and the DC-28 dust collector due to decommissioning. NGSC has also previously requested (November 2022) to change the identification of BO-7 (old) to BO-9 (new) and BO-8 (old) to BO-10 (new). Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Sources and Emissions Calculations 3 Ramboll 3. SOURCES AND EMISSIONS CALCULATIONS Pollutants emitted from the Facility’s operations include carbon monoxide (CO), nitrogen oxides (NOX), sulfur dioxide (SO2), VOCs, particulate matter (PM), greenhouse gases (GHGs), and HAPs. The following sections provide background on the methodology used to estimate potential emissions from the Facility’s proposed modifications to operations. Detailed potential emissions calculations are included in Appendix C. 3.1 Kiln NGSC proposes to install one electric kiln (IR&D Kiln) which will be used to vitrify ceramics at a high temperature. The firing process burns off organic matter in the ceramic and removes all water embedded in the atomic structure. The kiln is electric and will have ductwork designed to remove off-gassing products through a stack. Kiln emission rates are based engineering design data and Section 11.7 of the Environmental Protection Agency’s (EPA’s) AP-42 emission factor document.3 AP-42 does not contain any emission factors for electric kilns; however we conservatively used the natural gas-fired kiln emission factors for PM, NOx, CO, and VOC. AP-42 also presents emissions factors for CO2, SO2, hydrogen fluoride, and fluorides. However, these were determined not to be applicable. The CO2 and SO2 emission factors are fuel based emission factors based on natural gas combustion and are not reflective of the electric-fired kiln. Additionally, the process will not generate fluoride emissions based on engineering design data. The AP-42 emission factors are provided in units of pound of pollutant per ton of ceramic product (lb/ton). Emissions are calculated based on 184 lb of ceramic parts loaded in the kiln per run. Annual emissions are calculated based on continuous operation of the kiln, with each run lasting 3 days (no downtime for loading and unloading). The process will have the potential to generate ammonia (NH3) and some CO2. Emissions of these pollutants are calculated using mass-balance assuming 10 percent mass loss during each 3-day run. The total mass lost during each run is calculated and the emissions of the other pollutants subtracted (those calculated using the AP-42). As there is no speciation information for the process, it is conservatively assumed that the remaining mass could be either all NH3 or all CO2. The only HAP expected to be off-gassed is phenol, based on engineering design data. As there is not an AP-42 emission rate provided for phenol, it was conservatively assumed that all emitted VOC is phenol. 3.2 Electric Oven NGSC proposes to install one electric oven (IR&D Oven) which will be used to cure a thermoset resin in order to make the product infusible, insoluble, and unable to return to its uncured state. There will be ductwork designed to remove off-gassing products through a stack. HAP and VOC off-gas emissions rates were determined from on-site sample data. A 15- minute sample was taken from the exhaust stream of an oven when the oven reached the maximum cure temperature. In calculating emissions, it is assumed these emission rates are constant throughout the cure cycle which provides a conservative estimate of the amount of off-gassed product as VOC emission rates will decrease throughout the curing process. Emission rates are calculated based on the pollutant concentration and the maximum rated flow rate of the oven fan (310 acfm). Annual emissions are conservatively based on continuous operation for 8,760 hours per year (hr/yr). 3 AP-42, Chapter 11.7: Ceramic Clay Manufacturing. Available online at: https://www.epa.gov/sites/default/files/2020-10/documents/c11s07.pdf Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Sources and Emissions Calculations 4 Ramboll 3.3 Natural Gas-Fired Oven NGSC proposes to install one natural gas-fired oven (O-52) with a maximum rated capacity of 1.0 MMBtu/hr. The oven will be used to cure thermoset resin in order to make the product infusible, insoluble, and unable to return to its uncured state. Oven emission rates are based Section 1.4 of the EPA’s AP-42 emission factor document.4 Hourly emissions were calculated using the maximum rated capacity of the oven, and annual emissions are conservatively based on continuous operation for 8,760 hr/yr. Additionally, off-gassing may occur during unbagged cures, less than 5 percent of cures performed in the oven. Off-gassing of the film adhesive could result in 1 lb VOC emissions calculated based on the total weight lost as VOCs (accounting for water vapor regained) multiplied by the total mass cured for the year. From the SDS for the film adhesive, no HAPs are off-gassed.5 3.4 Spray Booth NGSC proposes to install one spray booth designed to remove overspray and vapors produced during paint spraying operations. The spray booth is a “tent and vent” configuration where a tent is temporarily set up and emissions from the operation will be vented to the outside of the building. VOC and PM emissions are the only emissions from the spray booth. Usage is calculated as a per day volume used and pounds used are based on the density of the respective paint. Emissions of VOCs and HAPs are calculated using the VOC or HAP content (volume percent), the density, and the expected gallons of the respective paint used per year. Emissions are conservatively based on all VOC and HAP being emitted via the stack. Emissions of PM are calculated using the solids content (volume percent) and multiplying this by the density and gallons used per year for each respective paint. Both controlled and uncontrolled emissions are calculated. Controlled PM emissions account for the control efficiency of the HVLP spray gun (65%) and the fabric filter efficiency (97.5%). Also, due to spraying, all PM emissions are assumed to be PM2.5. 3.5 Receiving Hood Exhaust NGSC proposes to install a receiving hood above a platen press that will capture emissions resulting from peroxide-curing of rubber. VOC emissions will be the only emissions exhausted through the receiving hood and are based on the mass of rubber cured per year. The receiving hood exhaust emissions are estimated using emissions factors for VOC and HAPs from Section 4.12 of the EPA’s AP-42 emission factor document.6 Emissions are calculated based on a maximum of 11 shipsets per year, assuming 913 feet (ft) of rubber per shipset, at a mass of 167 lb rubber per 300 ft roll (5,591 lb rubber per year). Although AP-42 Chapter 4.12 emission factors are proposed and not yet finalized, the emission factors for the use of the Platen Press with curing compound #9 (an unextruded peroxide cure) best represents the processes that will be used by NGSC. 3.6 Equipment Removal NGSC proposes to remove the SB-2 Laboratory Hood, E-145 Exhaust Hood, HR-3 Hot Room, and DC-28 Dust Collector. The SB-2 Laboratory Hood and E-145 Exhaust Hood only 4 AP-42, Chapter 1.4: Natural Gas Combustion. Available online at: https://www3.epa.gov/ttnchie1/ap42/ch01/final/c01s04.pdf 5 SDS for FM 300 6 AP-42, Chapter 4.12: Manufacture of Rubber Products. Available online at: https://www.epa.gov/sites/default/files/2020-10/documents/d04s12.pdf Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Sources and Emissions Calculations 5 Ramboll contribute to VOC and HAP emissions which are permitted as a facility-wide limit, therefore emission reductions due to their removal were not calculated. The removal of the HR-3 Hot Room will result in emission reductions for NOx, CO, PM (total), SO2, VOC, NH3, CO2, NH4, and N2O. These emission reductions were calculated using AP-42 Chapter 1.4 emission factors for natural gas combustion as well as ammonia emission factors for natural gas combustion from the EPA Development and Selection of Ammonia Emission Factors.7,8 Additionally, the removal of the DC-28 Dust Collector will result in emission reduction for PM10 and PM2.5. To evaluate emission reductions, a grain loading emission rate of 0.016 grains per cubic foot was used which is consistent with previous emission calculations for DC-28. 3.7 Emissions Summary Table 1 summarizes the Facility’s maximum annual controlled emissions for each pollutant. Documentation of uncontrolled and controlled emissions are provided in Appendix C. As discussed in Sections 4.1 and 4.2, the total emissions are compared to the federal NSR and Title V major source thresholds, and project emissions are compared to UDAQ modeling thresholds. As provided in Table 1, emissions are below all regulatory thresholds and modeling is not required for the project. Note that NGCS is not proposing to modify the existing facility-wide VOC and HAP permit limits. 7 AP-42, Chapter 1.4: Natural Gas Combustion. Available online at: https://www.epa.gov/sites/default/files/2020-09/documents/1.4_natural_gas_combustion.pdf 8 Development and Selection of Ammonia Emission Factors, Section 5: Ammonia Emissions from Combustion. Available online at: https://www3.epa.gov/ttnchie1/old/efdocs/ammonia.pdf Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Sources and Emissions Calculations 6 Ramboll Table 1: Maximum Annual Controlled Facility Emissions (PTE) Emission Source Category CO NOX PM10 PM2.5 SO2 VOC1 Total HAP1 Max HAP CO2e (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) (TPY) Currently Permitted Facility- Wide Potential Emissions 16.38 19.49 13.42 13.21 0.15 69.00 19.00 -- 24,245.00 IR&D Kiln 0.0185 3.0E-03 2.7E-03 2.7E-03 -- 2.4E-03 5.5E-04 5.5E-04 1.09 IR&D Oven -- -- -- -- -- 0.01 1.6E-05 1.4E-05 -- O-52 Oven 0.35 0.42 0.032 0.032 0.0025 0.024 0.0018 0.0017 506.26 Spray Booth -- -- -- 0.13 -- 1.2 0.025 0.016 -- Receiving Hood Exhaust -- -- -- -- -- 0.0049 3.2E-04 2.8E-04 -- Removed HR-3 Hot Room -0.030 -0.036 -2.7E-03 -2.7E-03 -2.2E-04 -2.0E-03 -1.6E-04 -1.5E-04 -43.53 Removed DC-28 Dust Collector -- -- -0.42 -0.42 -- -- -- -- -- Total Emissions 16.72 19.88 13.03 12.95 0.15 69.00 19.00 -- 24,708.82 Modeling Thresholds 100 40 15 -- 40 -- -- See App. C -- NSR Thresholds 250 70/10 0 250 70 70 70/100 -- -- -- Title V Thresholds 100 70 100 70 70 70 25 10 -- Exceeds Any Threshold? No No No No No No No No -- 1 NGSC is not requesting to modify its existing facility-wide VOC and HAP limits in Approval Order DAQE- AN101520028-22. Equipment specific emissions are presented here for reference but will operated within the existing limits. Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Federal and State Regulatory Applicability 7 Ramboll 4. FEDERAL AND STATE REGULATORY APPLICABILITY The following sections outline applicability of certain federal and state air regulations to the Facility’s proposed operations. Specifically, potentially applicable requirements under federal NSR, Title V of the Clean Air Act Amendments, New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAP), Chemical Accident Prevention Provisions, and Title R307 of the UAC are discussed herein. 4.1 New Source Review The federal NSR permitting program applies to major stationary sources of regulated air pollutants. The federal NSR program is comprised of two elements: Nonattainment NSR (NNSR) and Prevention of Significant Deterioration (PSD). NNSR permitting is applicable in areas that have been designated as nonattainment for a regulated pollutant under the National Ambient Air Quality Standards (NAAQS). PSD permitting applies in areas that have been designated as attainment or unclassifiable. The Facility is located 10 miles south of Ogden and 28 miles north of Salt Lake City, in Davis County. Davis County is a serious nonattainment for PM2.5 and moderate nonattainment for ozone (O3). As such, NNSR is the applicable program for ground-level ozone formation (VOCs and NOX) and PM2.5. PSD is the relevant NSR permitting program for all other criteria pollutants. Under the PM2.5 nonattainment designation, the NNSR major source threshold for PM2.5 and its precursors (NOX, VOC, SO2, and NH3) is 70 TPY. The NNSR major source threshold for NOX and VOC under the ozone nonattainment designation is 100 TPY. The major source threshold for all other regulated criteria pollutants is the PSD threshold of 250 TPY. The Facility will be classified as a minor source with respect to NNSR and PSD, as the facility- wide potential emissions will not exceed the major source thresholds. UDAQ is anticipating the reclassification of Northern Wasatch Front (NWF) ozone nonattainment from moderate to serious in February 2025. This means that stationary sources with the potential to emit (PTE) of greater than 50 TPY of NOx or VOCs will be designated a major source. These changes will make the Facility a major source with respect to VOC emissions following the reclassification of the ozone nonattainment to serious. 4.2 Title V Operating Permits The Title V operating permit program, promulgated in 40 CFR 70 and implemented in R307- 415 of the UAC, requires a facility to obtain a Title V operating permit if it has potential emissions of a regulated criteria pollutant exceeding 100 TPY (or 70 TPY for PM2.5 and its precursors), any single HAP exceeding 10 TPY, or total combined HAP emissions in excess of 25 TPY. Emissions from fugitive sources are not counted toward the Title V major source thresholds as aerospace structures manufacturing is not on the list of 28 source categories for which fugitive emissions must be included. The facility-wide potential emissions from non-fugitive emission sources do not exceed the Title V emission limits, therefore, the Facility is a minor source with respect to Title V. 4.3 New Source Performance Standards NSPS, promulgated in 40 CFR 60 and incorporated by reference in R307-210-1 of the UAC, provide emissions standards for criteria pollutant emissions from new, modified, and reconstructed sources. There are no potentially applicable NSPS standards that apply to the proposed operations at the Facility. 4.4 National Emission Standards for Hazardous Air Pollutants NESHAP, promulgated in 40 CFR 63 and incorporated by reference in R307-214-1 of the UAC, regulate emissions of HAP from specific source categories. A facility that has potential emissions exceeding 10 TPY for any individual HAP and/or emissions exceeding 25 TPY for Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Federal and State Regulatory Applicability 8 Ramboll the sum of all HAP is classified as a major source of HAP emissions. A facility that is not a major source of HAP is classified as an area source. Annual HAP emissions for the Facility are presented in Appendix C. The Facility is an area source for HAPs as they are below the 10 and 25 TPY limits. There are no potentially applicable NESHAP standards that apply to the proposed operations at the Facility. 4.5 Utah Administrative Code, Title R307 – Environmental Quality, Air Quality In addition to the federal regulations, Title R307 of the UAC establishes regulations applicable at the emission unit level and at the facility level. The state regulations also include general requirements for facilities, such as the requirement to obtain construction and operating permits. Source specific standards in R307 that are potentially applicable to the Facility’s proposed operations are discussed in the following sections. 4.5.1 R307-201 – Emission Standards: General Emission Standards This regulation sets general emission standards for opacity. Visible emissions from installations constructed after 1971 are limited to no more than 20% opacity for sources that are not diesel engines and no more than 40% for diesel engines.9 These standards cannot be exceeded except for short time periods during startup or shutdown, installation or operation, or unavoidable combustion irregularities which do not exceed three minutes in length. NGSC is required to minimize emissions during startup or shutdown, installation, or operation through the use of adequate controls and proper procedures.10 4.5.2 R307-410 – Emissions Impact Analysis The provisions of R307-410 establish the procedures and requirements for evaluating the emissions impact of new and modified sources that require an approval order under R307- 401 to ensure that the source will not interfere with the attainment or maintenance of any NAAQS in the state of Utah. As discussed in Chapter 3, project emissions are below modeling thresholds and no emissions impact analysis is required. 9 R307-201-3(2) & (6) 10 R307-201-3(7) Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 9 Ramboll 5. EVALUATION OF BEST AVAILABLE CONTROL TECHNOLOGY New and modified sources of air emissions in an attainment area in Utah are required to implement Best Available Control Technology (BACT) for control of emissions when applying for an AO.11 Determination of BACT accounts for the technical feasibility of potential air pollution control technologies, as well as factors such as the energy, environmental, and economic impacts of the technology. This section evaluates BACT for emissions of criteria pollutants from the Facility’s operations, specifically NOX, CO, VOC, PM10, PM2.5, and SO2. 5.1 BACT Analysis Process Utah air regulations [R307-401-5(2)(d)] require that BACT be used to minimize the emissions of pollutants from proposed new emission sources or modifications to existing emissions sources requiring an AO. BACT is defined as follows:12 [BACT] means an emissions limitation … based on the maximum degree of reduction for each air pollutant which would be emitted from any proposed stationary source or modification which the director, on a case-by-case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such source or modification through application of production processes or available methods, systems, and techniques, including fuel cleaning or treatment or innovative fuel combustion techniques for control of such pollutant. In no event shall application of best available control technology result in emissions of any pollutant which would exceed the emissions allowed by any applicable standard under 40 CFR parts 60 and 61. If the director determines that technological or economic limitations on the application of measurement methodology to a particular emissions unit would make the imposition of an emissions standard infeasible, a design, equipment, work practice, operational standard or combination thereof, may be prescribed instead to satisfy the requirement for the application of best available control technology. Such standard shall, to the degree possible, set forth the emissions reduction achievable by implementation of such design, equipment, work practice or operation, and shall provide for compliance by means which achieve equivalent results. The BACT analysis is performed on a pollutant-specific, case-by-case basis for each new or modified emission unit. The following emission units and pollutants were considered in the BACT analysis: ● IR&D Kiln: NOx, CO, VOC, PM10, PM2.5 ● IR&D Oven: VOC ● O-52 Oven: NOx, CO, VOC, PM10, PM2.5, SO2 ● Spray Booth: VOC, PM2.5 ● Receiving Hood Exhaust: VOC 11 R307-401-5(2)(d) 12 R307-401-2 Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 10 Ramboll 5.1.1 “Top-Down” BACT Approach This BACT analysis generally follows the “top-down” BACT approach outlined by EPA in a 1987 memorandum designed to improve the effectiveness of the federal PSD program.13,14 The top-down BACT approach starts with consideration of the technology that would achieve the maximum degree of emissions limitations, i.e. the lowest emission rate, which can be or has been applied to the specific source type under review or to other similar source types. The top-ranked technology may be eliminated based on costs, economics, environmental or energy impacts. If the top control option is eliminated, the BACT analysis then proceeds to the next most stringent technology and the analysis continues until a BACT conclusion is reached. The following steps provide a general outline of the top-down BACT process. In practice, each step may not apply to each BACT analysis, and the steps may be overlapping, combined, or undertaken in a different order depending on the specific emission units and considerations involved. 5.1.1.1 Step 1 – Identify Available Control Technologies The first step in the top-down procedure is to identify all available control technologies and emission reduction options for the emissions unit and pollutant undergoing the BACT analysis. Available control technologies are those with a practical potential for application to the pollutant and emission unit under review, which have been demonstrated in practice on full scale operations and are commercially available. Pollutant emission reduction options can be grouped into two categories: ● Inherently lower-emitting processes, practices, or designs; and ● Add-on control technologies. In addition, emission reduction options can sometimes be used in combination. 5.1.1.2 Step 2 – Eliminate Technically Infeasible Options The second step is to evaluate the technical feasibility of the control options identified in Step 1 and to eliminate any options that are technically infeasible based on engineering evaluation or due to chemical or physical principles. Criteria such as the following may be considered in determining technical feasibility: previous commercial scale demonstrations, precedents based on previous permits, and technology transfer from similar emission units. Technologies which have not yet been applied to full scale operations need not be considered available; an applicant should be able to purchase or construct a process or control device that has already been demonstrated in practice. When evaluating the technical feasibility of a technology that has been operated successfully on a type of source different than the source type under review, EPA has indicated that the “availability” and “applicability” of the technology to the source type under review should be considered to eliminate the technology as technically infeasible. EPA has stated that it “considers a technology to be ‘available’ where it can be obtained through commercial channels or is otherwise available within the common meaning of the term.”15 Further, EPA “considers an available technology to be ‘applicable’ if it can reasonably be installed and operated on the source type under consideration.”16 13 Memo dated December 1, 1987, from J. Craig Potter (U.S. EPA Headquarters) to U.S. EPA Regional Administrators, titled “Improving New Source Review Implementation.” 14 US EPA, Office of Air Quality Planning and Standards. 1989. June 3. “Transmittal of Background Statement on Top-Down Best Available Control Technologies”. Available online: https://www.epa.gov/sites/production/files/2015-07/documents/topdawn.pdf 15 U.S. EPA. PSD and Title V Permitting Guidance for Greenhouse Gases, March 2011. https://www.epa.gov/sites/production/files/2015-07/documents/ghgguid.pdf 16 Ibid. Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 11 Ramboll If any of the control techniques cannot be successfully used on the emission units due to technical difficulties, this finding should be documented, and such control techniques are not considered further in the BACT analysis. 5.1.1.3 Step 3 – Rank Remaining Control Technologies In Step 3, the remaining control technologies are rank-ordered into a control hierarchy from most to least stringent. To the extent practical, this involves an assessment and documentation of the emissions control level or emissions limit achievable with each technically feasible alternative, considering the specific operating constraints of the emission units undergoing review. Generally accepted control efficiencies or ranges of control efficiencies are presented where control efficiencies vary and/or detailed information for the specific emission unit is not available. 5.1.1.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs A top-ranked control option may be rejected as BACT based on a consideration of cost, economic, environmental, and energy impacts. If the top-ranked option is not selected as BACT, the applicant should document the evaluation of the cost, economic, environmental, and/or energy impacts that leads to its rejection. If a control technology is determined to be infeasible based on high cost effectiveness, or to cause adverse economic, energy, or environmental impacts that would outweigh the benefits of the additional emissions reduction as compared to a lower ranked control, then the control technology is rejected as BACT, and the next most stringent control technique is considered in turn. Both average cost effectiveness and incremental cost effectiveness may be considered for the control options. Cost effectiveness is the annualized cost of control [in dollars ($)] divided by the mass of emissions (in tons) reduced or eliminated by that control. For a specific control technology, average cost effectiveness is the cost ($ per ton) that would be incurred compared with baseline conditions. Incremental cost effectiveness is the difference in cost per ton of emissions reduced at the next most stringent level of control when comparing two control options. A control cost analysis has not been provided since the baghouse selected is widely acceptable as BACT. 5.1.1.5 Step 5 – Select BACT BACT is identified as the option with the highest control effectiveness from Step 3 that is not eliminated in Step 4 based on consideration of cost, economic, energy or environmental impacts. Once the control technology, process or work practice is selected, a BACT emission limit is established, if appropriate, considering what is achievable over the range of operating conditions anticipated. 5.1.2 Information Relied Upon In general, the spectrum of BACT control options identified in Step 1 for consideration as potential control options is based on the following: ● An assessment of recently issued BACT determinations and permits for similar sources; ● EPA Air Pollution Control Technology Fact Sheets and other EPA guidance and technical reports were relied upon as a reference for the likely achievable range of control for control equipment and/or for guidance regarding the BACT process; ● Vendor data; and ● Professional engineering judgement and experience. Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 12 Ramboll 5.2 NOx BACT Analysis for IR&D Kiln 5.2.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for NOx include: ● Selective Catalytic Reduction (SCR); and ● Good Management Practices (GMP). Selective Catalytic Reduction (SCR) SCR is a method of NOx control that utilizes a catalyst and reagent to reduce NOx emissions. SCR is typically implemented on stationary source combustion units which require a high level of NOx reduction 17. Urea is generally used as the reduction reagent. NOx removal efficiencies for SCR are high, at 90 percent.18 SCR is considered technically infeasible on the IR&D kiln as SCR is generally applied to large combustion units (>100 MMBtu/hr), and SCR is most effective for exhaust streams with high temperatures and NOx concentrations. Good Management Practices (GMP) GMP is a method of emissions control involving proper maintenance and operations of the equipment. 5.2.2 Step 2 – Eliminate Technically Infeasible Options GMP is the only technically feasible control option. 5.2.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GMP was the only control technology identified. 5.2.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GMP was not further analyzed as it was the only control technology identified. 5.2.5 Step 5 – Select BACT NGSC proposes GMP as BACT for NOx emissions from the IR&D kiln. GMP is widely accepted as BACT for similar source types. 5.3 CO BACT Analysis for IR&D Kiln 5.3.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for CO include: ● Good Management Practices (GMP). Good Management Practices (GMP) GMP is a method of emissions control involving proper maintenance and operations of the equipment. 5.3.2 Step 2 – Eliminate Technically Infeasible Options The CO control option identified in Step 1 is considered technically feasible for the IR&D kiln. 5.3.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GMP was the only control technology identified. 17 EPA (2017). Air Pollution Control Cost Manual, Section 4 – Chapter 2. https://www.epa.gov/sites/default/files/2017- 12/documents/scrcostmanualchapter7thedition_2016revisions2017.pdf 18 EPA. Air Pollution Control Technology Fact Sheet – SCR. https://www3.epa.gov/ttncatc1/dir1/fscr.pdf Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 13 Ramboll 5.3.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GMP was not further analyzed as it was the only control technology identified. 5.3.5 Step 5 – Select BACT NGSC has selected GMP as BACT for CO emissions from the IR&D kiln. GMP is widely accepted as BACT for similar source types. 5.4 VOC BACT Analysis for IR&D Kiln 5.4.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for VOC include: ● Regenerative Thermal Oxidizer (RTO); ● Carbon Adsorption System; and ● Good Management Practices (GMP). Regenerative Thermal Oxidizer (RTO) RTOs are the most common type of thermal oxidizer technology. RTOs typically use ceramic direct contact heat exchangers to achieve temperatures high enough to ignite the waste stream and destroy VOCs/HAPs. RTOs are considered technically infeasible for the IR&D kiln as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the flue gas. Carbon Adsorption System Carbon adsorption generally involves the adsorption of organic compounds on activated carbon. Adsorption is most effective at lower temperatures and is affected by ambient humidity. Periodic replacement of the activated carbon is required as buildup of compounds on the filter media will occur. Carbon adsorption is considered technically infeasible for the IR&D kiln as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the flue gas. Good Management Practices (GMP) GMP is a method of emissions control involving proper maintenance and operations of the equipment. 5.4.2 Step 2 – Eliminate Technically Infeasible Options GMP is the only technically feasible control technology remaining. 5.4.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GMP was the only control technology identified. 5.4.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GMP was not further analyzed as it was the only control technology identified. 5.4.5 Step 5 – Select BACT NGSC has selected GMP as BACT for VOC emissions from the IR&D kiln. GMP is widely accepted as BACT for similar source types. 5.5 PM BACT Analysis for IR&D Kiln 5.5.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for PM include: Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 14 Ramboll ● Electrostatic Precipitator (ESP); ● Wet Scrubber; ● Baghouse; and ● Good Management Practices (GMP). Electrostatic Precipitator (ESP) ESPs remove PM from exhaust by applying a high-voltage electrostatic charge and collecting the particles on charged plates. ESPs are filterless devices that can remove fine particles. Dry ESPs involve the removal of collected particles as dry material while wet ESPs remove collected particles by washing the charged plates with water. ESPs are considered technically infeasible for the IR&D kiln as they are most effective on metals and items of high resistivity. Additionally, there is concern from NGSC about the high voltage required by ESPs. Wet Scrubber Wet scrubbers remove liquid or solid particles from a gas stream by transferring them to a liquid, which is often water. All wet scrubbers include mist eliminators or entrainment separators to remove entrained droplets. Wet scrubbers are considered technically infeasible for use on the IR&D kiln as they are generally not used for fine particles, which is the majority of the PM that will be emitted from the kiln. Baghouse Baghouses are dust collectors made of fabric filters that remove particulate matter via filtration. There are different configurations for baghouses, which vary based on the method of cleaning out inundate fabric filters. There are reverse air, pulse jet, and shaker baghouses. Baghouses are considered technically infeasible for the IR&D kiln as they are generally not used in practice for similarly sized equipment. Good Management Practices (GMP) GMP is a method of emissions control involving proper maintenance and operations of the equipment. 5.5.2 Step 2 – Eliminate Technically Infeasible Options GMP is the only technically feasible control technology remaining. 5.5.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GMP was the only control technology identified. 5.5.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GMP was not further analyzed as it was the only control technology identified. 5.5.5 Step 5 – Select BACT NGSC has selected GMP as BACT for PM emissions from the IR&D kiln. GMP is widely accepted as BACT for similar source types. 5.6 VOC BACT Analysis for IR&D Oven 5.6.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for VOC include: ● Regenerative Thermal Oxidizer (RTO); ● Carbon Adsorption System; Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 15 Ramboll ● Good Management Practices (GMP). Regenerative Thermal Oxidizer (RTO) RTOs are the most common type of thermal oxidizer technology. RTOs typically use ceramic direct contact heat exchangers to achieve temperatures high enough to ignite the waste stream and destroy VOCs/HAPs. RTOs are considered technically infeasible for the IR&D oven as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the flue gas. Carbon Adsorption System Carbon adsorption generally involves the adsorption of organic compounds on activated carbon. Adsorption is most effective at lower temperatures and is affected by ambient humidity. Periodic replacement of the activated carbon is required as buildup of compounds on the filter media will occur. Carbon adsorption is considered technically infeasible for the IR&D oven as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the flue gas. Good Management Practices (GMP) GMP is a method of emissions control involving proper maintenance and operations of the equipment. 5.6.2 Step 2 – Eliminate Technically Infeasible Options GMP is the only technically feasible control technology remaining. 5.6.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GMP was the only control technology identified. 5.6.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GMP was not further analyzed as it was the only control technology identified. 5.6.5 Step 5 – Select BACT NGSC has selected GMP as BACT for VOC emissions from the IR&D oven. GMP is widely accepted as BACT for similar source types. 5.7 NOx BACT Analysis for O-52 Oven 5.7.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for NOx include: ● Flue Gas Recirculation (FGR); ● Selective Catalytic Reduction (SCR); ● Combustion Controls (Low-NOx and ultra-low NOx burners, LNB/ULNB); and ● Good Combustion Practices (GCP). Flue Gas Recirculation (FGR) FGR is a NOx control technology wherein the exhaust gas is routed into the inlet with the addition of a forced hot gas fan.19 FGR is most effective for natural gas and low-nitrogen fuels because it lowers the available oxygen which reduces the formation of NOx. The NOx capture efficiency of FGR is 30-60 percent.20 FGR is considered technically infeasible on the 19 Power Engineering (2003). NOx Control on a Budget: Induced Flue Gas Recirculation. https://www.power- eng.com/news/nosubx-sub-control-on-a-budget-induced-flue-gas-recirculation/#gref 20 Pollution Online (2000). NOx Emission Reduction Strategies. https://www.pollutiononline.com/doc/nox-emission- reduction-strategies-0001 Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 16 Ramboll O-52 oven as flue gas recirculation adds an inconsistent heat output element to the fuel, which is unsuitable for NGSC as tight temperature tolerances for the process require the gas stream to maintain a constant heat output value. Selective Catalytic Reduction (SCR) SCR is a method of NOx control that utilizes a catalyst and reagent to reduce NOx emissions. SCR is typically implemented on stationary source combustion units which require a high level of NOx reduction 21. Urea is generally used as the reduction reagent. NOx removal efficiencies for SCR are high, at 90 percent.22 SCR is considered technically infeasible on the O-52 oven as SCR is generally applied to large combustion units (>100 MMBtu/hr), and SCR is most effective for exhaust streams with high temperatures and NOx concentrations. Combustion Controls (Low-NOx and ultra-low NOx burners, LNB/ULNB) NOx formation can be reduced through the restriction of oxygen, flame temperature, or residence time, which is the principle of LNB technology. Staged fuel and staged air burners are both intended to reduce the formation of thermal NOx. When LNB technology is implemented, emissions of NOx can be reduced by 50 percent compared to standard burners.23 An ULNB is a type of LNB that can reduce NOx emissions to very low levels, usually below 30 ppmv, corrected to 3 percent oxygen.24 ULNB technology has been shown to achieve NOx emissions of 9 ppmv.25 LNB/ULNB technology is considered technically infeasible as controls are not demonstrated in practice for natural-gas fired equipment with firing rates less than 10 MMBtu/hr. Good Combustion Practices (GCP) GMP is a method of emissions control involving proper maintenance and operations of combustion equipment. Some GMPs are the use of natural gas as fuel, proper air ratios, and routine tune-ups. 5.7.2 Step 2 – Eliminate Technically Infeasible Options GCP is the only technically feasible control option. 5.7.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GCP was the only control technology identified. 5.7.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GCP was not further analyzed as it was the only control technology identified. 21 EPA (2017). Air Pollution Control Cost Manual, Section 4 – Chapter 2. https://www.epa.gov/sites/default/files/2017- 12/documents/scrcostmanualchapter7thedition_2016revisions2017.pdf 22 EPA. Air Pollution Control Technology Fact Sheet – SCR. https://www3.epa.gov/ttncatc1/dir1/fscr.pdf 23 AP‐42 Table 1.4‐1 – Emission Factors for Nitrogen Oxides (NOx) and Carbon Monoxide (CO) from Natural Gas Combustion. https://www3.epa.gov/ttnchie1/ap42/ch01/final/c01s04.pdf 24 Oak Ridge National Laboratory (2002). Guide to Low‐Emission Boiler and Combustion Equipment Selection. https://www.energy.gov/eere/amo/articles/guide‐low‐emission‐boiler‐and‐combustion‐equipment‐ selection 25 Power Flame. Nova Low NOx Burners. https://www.powerflame.com/index.php?option=com_content&view=article&id=110&Itemid =57; Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 17 Ramboll 5.7.5 Step 5 – Select BACT NGSC has selected GMP as BACT for NOx emissions from the O-52 oven. GMP is widely accepted as BACT for similar source types. 5.8 CO BACT Analysis for O-52 Oven 5.8.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for CO include: ● Good Combustion Practices (GCP). Good Combustion Practices (GCP) GCP is a method of emissions control involving proper maintenance and operations of combustion equipment. Some GCPs are the use of natural gas as fuel, proper air ratios, and routine tune-ups. 5.8.2 Step 2 – Eliminate Technically Infeasible Options The CO control option identified in Step 1 is considered technically feasible for the IR&D kiln. 5.8.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GCP was the only control technology identified. 5.8.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GCP was not further analyzed as it was the only control technology identified. 5.8.5 Step 5 – Select BACT NGSC has selected GCP as BACT for CO emissions from the IR&D kiln. GCP is widely accepted as BACT for similar source types. 5.9 VOC BACT Analysis for O-52 Oven 5.9.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for VOC include: ● Regenerative Thermal Oxidizer (RTO); ● Carbon Adsorption System; ● Good Combustion Practices (GCP). Regenerative Thermal Oxidizer (RTO) RTOs are the most common type of thermal oxidizer technology. RTOs typically use ceramic direct contact heat exchangers to achieve temperatures high enough to ignite the waste stream and destroy VOCs/HAPs. RTOs are considered technically infeasible for the O-52 oven as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the flue gas. Carbon Adsorption System Carbon adsorption generally involves the adsorption of organic compounds on activated carbon. Adsorption is most effective at lower temperatures and is affected by ambient humidity. Periodic replacement of the activated carbon is required as buildup of compounds on the filter media will occur. Carbon adsorption is considered technically infeasible for the O-52 oven as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the flue gas. Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 18 Ramboll Good Combustion Practices (GCP) GCP is a method of emissions control involving proper maintenance and operations of the equipment. Some GCPs are the use of natural gas as fuel, proper air ratios, and routine tune-ups. 5.9.2 Step 2 – Eliminate Technically Infeasible Options GCP is the only technically feasible control technology remaining. 5.9.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GCP was the only control technology identified. 5.9.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GCP was not further analyzed as it was the only control technology identified. 5.9.5 Step 5 – Select BACT NGSC has selected GCP as BACT for VOC emissions from the IR&D oven. GCP is widely accepted as BACT for similar source types. 5.10 PM BACT Analysis for O-52 Oven 5.10.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for PM include: ● Electrostatic Precipitator (ESP); ● Wet Scrubber; ● Baghouse; and ● Good Combustion Practices (GCP). Electrostatic Precipitator (ESP) ESPs remove PM from exhaust by applying a high-voltage electrostatic charge and collecting the particles on charged plates. ESPs are filterless devices that can remove fine particles. Dry ESPs involve the removal of collected particles as dry material while wet ESPs remove collected particles by washing the charged plates with water. ESPs are considered technically infeasible for the O-52 oven as they are most effective on metals and items of high resistivity. Additionally, there is concern from NGSC about the high voltage required by ESPs. Wet Scrubber Wet scrubbers remove liquid or solid particles from a gas stream by transferring them to a liquid, which is often water. All wet scrubbers include mist eliminators or entrainment separators to remove entrained droplets. Wet scrubbers are considered technically infeasible for use on the O-52 oven as they are generally not used for fine particles, which is the majority of the PM that will be emitted from the kiln. Baghouse Baghouses are dust collectors made of fabric filters that remove particulate matter via filtration. There are different configurations for baghouses, which vary based on the method of cleaning out inundate fabric filters. There are reverse air, pulse jet, and shaker baghouses. Baghouses are considered technically infeasible for the O-52 oven as they are generally not used in practice for similarly sized equipment. Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 19 Ramboll Good Combustion Practices (GCP) GCP is a method of emissions control involving proper maintenance and operations of the equipment. Some GCPs are the use of natural gas as fuel, proper air ratios, and routine tune-ups. 5.10.2 Step 2 – Eliminate Technically Infeasible Options GCP is the only technically feasible control technology remaining. 5.10.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GCP was the only control technology identified. 5.10.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GCP was not further analyzed as it was the only control technology identified. 5.10.5 Step 5 – Select BACT NGSC has selected GCP as BACT for PM emissions from the O-52 oven. GCP is widely accepted as BACT for similar source types. 5.11 SO2 BACT Analysis for O-52 Oven 5.11.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for SO2 include: ● Wet Scrubber; ● Low Sulfur Fuels; and ● Good Combustion Practices (GCP). Wet Scrubber Wet scrubbers remove liquid or solid particles from a gas stream by transferring them to a liquid, which is often water. All wet scrubbers include mist eliminators or entrainment separators to remove entrained droplets. Wet scrubbers are considered technically infeasible for use on the O-52 oven as they are generally used for streams with high SO2 concentrations, which NGSC’s O-52 oven does not have. Low Sulfur Fuels Low sulfur fuels such as natural gas reduce SO2 emissions compared to high sulfur fuels such as coal. Use of natural gas is considered technically feasible for use on the O-52 oven. Good Combustion Practices (GCP) GCP is a method of emissions control involving proper maintenance and operations of the equipment. Some GCPs are the use of natural gas as fuel, proper air ratios, and routine tune-ups. 5.11.2 Step 2 – Eliminate Technically Infeasible Options Low sulfur fuels and GCP are the only technically feasible control technology remaining. 5.11.3 Step 3 – Rank Remaining Control Technologies No ranking was performed for low sulfur fuels and GCP. Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 20 Ramboll 5.11.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs Low sulfur fuels and GCP were not further analyzed as they will both be considered in the next step. 5.11.5 Step 5 – Select BACT NGSC has selected the use of low sulfur fuels and GCP as BACT for PM emissions from the O- 52 oven. Natural gas as fuel and GCP is widely accepted as BACT for similar source types. 5.12 VOC BACT Analysis for Spray Booth 5.12.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for VOC include: ● Regenerative Thermal Oxidizer (RTO); ● Carbon Adsorption System; ● Compliance with Utah R307-355 Aerospace Coatings Rule; and ● Good Management Practices (GMP). Regenerative Thermal Oxidizer (RTO) RTOs are the most common type of thermal oxidizer technology. RTOs typically use ceramic direct contact heat exchangers to achieve temperatures high enough to ignite the waste stream and destroy VOCs/HAPs. RTOs are considered technically infeasible for the spray booth as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the flue gas. Carbon Adsorption System Carbon adsorption generally involves the adsorption of organic compounds on activated carbon. Adsorption is most effective at lower temperatures and is affected by ambient humidity. Periodic replacement of the activated carbon is required as buildup of compounds on the filter media will occur. Carbon adsorption is considered technically feasible for the spray booth. Compliance with Utah R307-355 Aerospace Coatings Rule The R307-355 Aerospace Coatings Rule outlines regulations to limit emissions of VOCs from aerospace coatings and adhesives, from organic solvent cleaning and from the storage and disposal of solvents and waste solvent material. The rule includes VOC content limits for different coating types. Compliance with R307-355 is considered technically feasible for the spray booth. Good Management Practices (GMP) GMP is a method of emissions control involving proper maintenance and operations of the equipment. GMP for a spray booth involves closing containers when they are not in use and promptly cleaning up spills, among other techniques. 5.12.2 Step 2 – Eliminate Technically Infeasible Options Carbon adsorption, compliance with R307-355, and GMP are the only technically feasible control technologies remaining. 5.12.3 Step 3 – Rank Remaining Control Technologies A carbon adsorption system is the highest ranked control option, followed by compliance with R307-355 and GMP. Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 21 Ramboll 5.12.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs As emissions of VOC from the spray booth are only 1.2 TPY, the cost of any add-on control system such as a carbon adsorption system is economically infeasible. In a 2019 BACT analysis, NGSC found that a carbon adsorber for a spray booth with a PTE of 0.54 TPY had a cost effectiveness of $2.6 million/ton of VOC for canister replacement and $187,565/ton of VOC for carbon replacement. As costs for these systems have not changed drastically, this is considered economically infeasible. Compliance with R307-355 and GMP were not further analyzed. 5.12.5 Step 5 – Select BACT NGSC has selected compliance with R307-355 and GMP as BACT for VOC emissions from the spray booth. These measures are widely accepted as BACT for similar source types. 5.13 PM BACT Analysis for Spray Booth 5.13.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for PM include: ● Electrostatic Precipitator (ESP); ● Baghouse; and ● HVLP Spray Guns. Electrostatic Precipitator (ESP) ESPs remove PM from exhaust by applying a high-voltage electrostatic charge and collecting the particles on charged plates. ESPs are filterless devices that can remove fine particles. Dry ESPs involve the removal of collected particles as dry material while wet ESPs remove collected particles by washing the charged plates with water. ESPs are considered technically infeasible for the spray booth as they are most effective on metals and items of high resistivity. Additionally, there is concern from NGSC about the high voltage required by ESPs. Baghouse Baghouses are dust collectors made of fabric filters that remove particulate matter via filtration. There are different configurations for baghouses, which vary based on the method of cleaning out inundate fabric filters. There are reverse air, pulse jet, and shaker baghouses. Baghouses are considered technically feasible for the spray booth as a tent-and- vent 3-stage fabric filter will be installed with the spray booth. HVLP Spray Guns HVLP spray guns are high-volume, low-pressure spray guns which reduce PM emissions from paint application. HVLP spray guns result in better coverage and less material loss. They are considered technically feasible for the spray booth as they are already in place on another of NGSC’s spray booths. 5.13.2 Step 2 – Eliminate Technically Infeasible Options Baghouses and HVLP spray guns are the only technically feasible control technologies remaining. 5.13.3 Step 3 – Rank Remaining Control Technologies No ranking was performed for the remaining control technologies Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Evaluation of Best Available Control Technology 22 Ramboll 5.13.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs Baghouses and HVLP spray guns were not further analyzed as they were the only control technologies identified. 5.13.5 Step 5 – Select BACT NGSC has selected a baghouse (or 3-stage fabric filter) and HVLP spray guns as BACT for PM emissions from the spray booth. These are widely accepted as BACT for similar source types. 5.14 VOC BACT Analysis for Receiving Hood Exhaust 5.14.1 Step 1 – Identify Available Control Technologies Potentially available control technologies for VOC include: ● Regenerative Thermal Oxidizer (RTO); ● Carbon Adsorption System; and ● Good Management Practices (GMP). Regenerative Thermal Oxidizer (RTO) RTOs are the most common type of thermal oxidizer technology. RTOs typically use ceramic direct contact heat exchangers to achieve temperatures high enough to ignite the waste stream and destroy VOCs/HAPs. RTOs are considered technically infeasible for the receiving hood exhaust as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the exhaust gas. Carbon Adsorption System Carbon adsorption generally involves the adsorption of organic compounds on activated carbon. Adsorption is most effective at lower temperatures and is affected by ambient humidity. Periodic replacement of the activated carbon is required as buildup of compounds on the filter media will occur. Carbon adsorption is considered technically infeasible for the receiving hood exhaust as thermal oxidizers are not effective to control VOCs when there are low VOC concentrations in the exhaust gas. Good Management Practices (GMP) GMP is a method of emissions control involving proper maintenance and operations of the equipment. 5.14.2 Step 2 – Eliminate Technically Infeasible Options GMP is the only technically feasible control technology remaining. 5.14.3 Step 3 – Rank Remaining Control Technologies No ranking was performed as GMP was the only control technology identified. 5.14.4 Step 4 – Evaluate Energy, Environmental, and Economic Impacts and Other Costs GMP was not further analyzed as it was the only control technology identified. 5.14.5 Step 5 – Select BACT NGSC has selected GMP as BACT for VOC emissions from the receiving hood exhaust. GMP is widely accepted as BACT for similar source types. Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Ramboll Confidenti al APPENDIX A FACILITY MAPS AND DIAGRAMS Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Ramboll Confidenti al APPENDIX B UDAQ NOI FORMS Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Confidenti al APPENDIX C POTENTIAL EMISSIONS CALCULATIONS Northrop Grumman Systems Corp. Clearfield Facility Notice of Intent Confidenti al APPENDIX D DETAILED PROCESS FLOW DIAGRAM 1 H5 (South) ACCE M9 & M11 G12 & G14 B13 (North) A15 (North) B14/C14/D14 DRAFT TPY TPY TPY TPY PM10 13 -0.42 0.035 13.0 PM2.5 13 -0.42 0.16 12.9 SO2 0.15 -2.2E-04 0.0025 0.15 NOX 19.5 -0.036 0.42 19.88 VOC 69 ----69 CO 16 -0.030 0.37 16.7 CO2e 24,245 -44 507 24,709 HAPs 19 ----19 Notes: 1. 2. 3. Current PTE are based on emissions listed in AO Summary of Emissions and Permit Condition II.B.2, DAQE-AN101520028-22. Total VOC and HAP emission limitations will not be changing with this modification. Reduction in emissions from removal of the HR-3 hot room and DC-28 dust collector. Removed ventilation and fume hood reduction in emissions were not quantified as NGSC is not proposing a limit change for VOC/HAPs. Increase in emissions due to the installation of an IR&D kiln, IR&D oven, O-52 oven, spray booth, and a receiving hood exhaust. Current Potential to Emit (PTE)1 Proposed Reduction2 Proposed Addition3 Proposed Potential to Emit (PTE) Table 1 Facility Potential to Emit - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah Pollutant 1 of 14 # Confidential DRAFT VOC NOx PM2.5 PM10 CO CO2 SOx NH3 Kiln IR&D Kiln 2.4E-03 3.0E-03 2.7E-03 2.7E-03 0.0185 1.09 --1.09 IR&D Oven 0.01 -------------- O-52 0.024 0.42 0.032 0.032 0.35 503 0.0025 0.013 Spray Booth Spray Booth 1.2 --0.13 ---------- Receiving Hood Exhaust Receiving Hood Exhaust 0.0049 -------------- Hot Room HR-3 -0.0020 -0.036 -0.0027 -0.0027 -0.030 -43 -2.2E-04 -0.0012 Dust Collector DC-28 -----0.42 -0.42 -------- Table 2 CAP Evaluation - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah Category Proposed/ Permitted Name Ovens Emissions (TPY) 2 of 14 Confidential DRAFT IR&D Kiln IR&D Oven O-52 Oven Spray Booth Receiving Hood Exhaust HR-3 Hot Room DC-28 Dust Collector 1,1,1-Trichloroethane --------2.7E-06 ----2.7E-06 1,3-Butadiene --------4.8E-06 ----4.8E-06 1,4-Dichlorobenzene(p)----1.1E-06 --------1.1E-06 2-Butanone --------1.9E-06 ----1.9E-06 Acetaldehyde --------4.9E-06 ----4.9E-06 Acetophenone --------2.8E-04 ----2.8E-04 Arsenic ----1.9E-07 -----1.6E-08 --1.8E-07 Benzene ----2.0E-06 -----1.7E-07 --1.8E-06 Beryllium -----------9.9E-10 ---9.9E-10 bis(2-Ethylhexyl)phthalate --------1.7E-06 ----1.7E-06 Cadmium ----1.1E-06 -----9.1E-08 --9.6E-07 Carbon Disulfide --------2.7E-06 ----2.7E-06 Chloromethane --2.1E-06 ----------2.1E-06 Chromium ----1.3E-06 -----1.2E-07 --1.2E-06 Cobalt ----8.0E-08 -----6.9E-09 --7.4E-08 Cumene --------1.8E-06 ----1.8E-06 Dimethylphthalate --------4.3E-08 ----4.3E-08 Di-n-butylphthalate --------4.6E-06 ----4.6E-06 Formaldehyde ----7.2E-05 9.0E-03 ---6.2E-06 --9.1E-03 Hexachlorobutadiene --------2.5E-07 ----2.5E-07 Hexane ----1.7E-03 --1.0E-05 -1.5E-04 --1.6E-03 Lead ----4.8E-07 -----4.1E-08 --4.4E-07 Manganese ----3.6E-07 -----3.1E-08 --3.3E-07 Mercury ----2.5E-07 -----2.1E-08 --2.3E-07 Methyl isobutyl ketone ------1.6E-02 ------1.6E-02 Methylene Chloride --------1.2E-06 ----1.2E-06 Naphthalene ----5.8E-07 --2.6E-06 -5.0E-08 --3.1E-06 Nickel ----2.0E-06 -----1.7E-07 --1.8E-06 Phenol 5.5E-04 ------8.2E-07 ----5.5E-04 Polycyclic Organic Matter -----------7.3E-09 ---7.3E-09 Selenium -----------2.0E-09 ---2.0E-09 Toluene --1.4E-05 3.3E-06 --1.7E-06 -2.8E-07 --1.9E-05 TOTAL 5.5E-04 1.6E-05 1.8E-03 2.5E-02 3.2E-04 -1.6E-04 0.0E+00 2.7E-02 Total Facility Emissions (lb/hr) Pollutant Table 3 HAP Evaluation - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah Emissions by Source (lb/hr) 3 of 14 Confidential DRAFT CO2 CH4 N2O HFCs PFCs SF6 Kiln1 IR&D Kiln --1.09 ----------1.09 IR&D Oven ---------------- O-52 O-52 503 0.010 0.0092 ------506 Spray Booth Spray Booth ---------------- Receiving Hood Exhaust Receiving Hood Exhaust ---------------- Hot Room HR-3 Hot Room HR-3 -43 -8.3E-04 -7.9E-04 -------44 Dust Collector DC-28 Dust Collector DC-28 -------------- Notes: 1. 2.GWPs from the 6th Assessment Report from the IPCC, https://report.ipcc.ch/ar6/wg1/IPCC_AR6_WGI_FullReport.pdf pg. 1017; using CH4- fossil and 100-yr GWP. CH4 and N2O emissions were not accounted for by AP-42 emission factors, and are considered de minimis. Table 4 GHG Evaluation Northrop Grumman Systems Corp. Clearfield, UT GHG Emissions (CO2e TPY)2 Oven Category Proposed/ Permitted Name Source Name Emissions (TPY) 4 of 14 Confidential Emissions Increase ETV1 Modeling Required? lbs/hr lb/hr 1,1,1-Trichloroethane 0 NA NA 1,1,2-Trichloroethane 0 NA NA 1,3-Butadiene 2.10E-05 7.52E-02 NO 1,4-Dichlorobenzene(p)5.03E-06 3.07E+00 NO 2-(2-Butoxyethoxy)-Ethanol 0 NA NA 2-Butanone 8.44E-06 3.01E+01 NO Acetaldehyde 2.14E-05 1.71E+00 NO Acetophenone 1.23E-03 2.51E+00 NO Arsenic 7.67E-07 5.00E-04 NO Benzene 8.05E-06 8.15E-02 NO Beryllium 0.00E+00 3.00E-06 NO bis(2-Ethylhexyl)phthalate 7.27E-06 2.55E-01 NO Cadmium 4.22E-06 3.40E-05 NO Carbon Disulfide 1.17E-05 1.59E-01 NO Chloromethane 9.14E-06 5.27E+00 NO Chromium 0 NA NA Cobalt 3.22E-07 1.00E-03 NO Cumene 0 NA NA Dimethylphthalate 1.88E-07 2.55E-01 NO Di-n-butylphthalate 2.00E-05 2.55E-01 NO Ethyl Acrylate 0 NA NA Ethyl Benzene 0 NA NA Ethylene Glycol 0 NA NA Formaldehyde 0 NA NA Generic HAPs 0 NA NA Glycol Ethers 0 NA NA Hexachlorobutadiene 1.10E-06 1.10E-02 NO Hexamethylene-1,6-Diisocyanate 0 NA NA Hexane 0 NA NA Hydrogen Fluoride (Hydrofluoric Acid)0 NA NA Lead 1.92E-06 NA NA Manganese 1.46E-06 1.00E-02 NO Mercury 9.97E-07 1.00E-03 NO Methanol 0 NA NA Methyl Isobutyl Ketone 0 NA NA Methyl Isocyanate 0 NA NA Methyl Methacrylate 0 NA NA Methylene Chloride (Dichloromethane)0 NA NA Methylenedianiline 0 NA NA Methylene Diphenyl Diisocyanate (MDI)0 NA NA Naphthalene 0 NA NA Nickel 0 NA NA Phenol 0 NA NA Polycyclic Organic Matter 0.00E+00 NA NA Selenium 0.00E+00 NA NA Styrene 0 NA NA Tetrachloroethylene (Perchloroethylene)0 NA NA Toluene 0 NA NA Trichloroethylene 0 NA NA Xylenes (Isomers and Mixture)0 NA NA TOTAL HAP 0.000 NA NA 1 ETV are calculated as a worst case, using ETFs for vertically restricted release points 20 meters or less from ambient air in accordance with R307-410-5. Table 5 HAP Air Dispersion Modeling Applicability Northrop Grumman Systems Corp. Clearfield, Utah HAP DRAFT Pollutant Emission Factor (lb/ton)1,2 Footnotes Emissions (lb/yr) Emissions (TPY)7 PM 0.49 --5.49 2.7E-03 SO2 44*S 3 N/A N/A NOx 0.54 --6.05 3.0E-03 CO 3.3 --37.00 1.8E-02 CO2 ----2186.6 1.09 VOC 0.43 --4.82 2.4E-03 HF 0.46 4 N/A N/A Fluorides 0.56 5 N/A N/A NH3 (Utah)--6 2186.6 1.09 Notes: 1. 2. 3. 4. 5. 6. 7. Emissions were calculated assuming 184 lb of ceramic parts are loaded in the kiln per run and each run lasts 3 day. Annual emissions are based on continuous operation of the kiln, for a total of 11.2 tons of ceramic parts loaded per year. Table 6 IR&D Kiln Emissions - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah PM emission factors from AP-42 Chapter 11.7, Table 11.7-1. All other emission factors, except CO2 and NH3, from AP-42 Chapter 11.7, Table 11.7-2. S represents the raw material sulfur content (percent). There is no sulfur in the raw material, so S was taken as zero. HF emissions were omitted as fluorides are not present in the fired ceramic. Fluoride emissions were omitted as fluorides are not present in the fired ceramic. CO2 and NH3 emissions were conservatively estimated by subtracting all other pollutant emissions (in tpy) from the annual mass lost assuming a 10% mass loss during each run (1.12 TPY). As there is no speciation information for the process, it is conservatively assumed that the remaining mass could be either all CO2 or all NH3. 6 of 14 Confidential DRAFT Chemical Emission Rate (μg/m3)VOC?HAP? Dichlorodifluoromethane 2.6 VOC Chloromethane 1.8 VOC HAP Acetone 250 VOC 2-Butanone 17 VOC Ethanol 339 VOC Isopropyl Alcohol 1,991 VOC Heptane 2.8 VOC 4-Methyl-2-pentanone 4.2 VOC Toluene 12 VOC HAP 2-Pentanone 23 VOC Chemical Emission Rate (lb/hr) Emissions (TPY) Chloromethane 2.09E-06 9.13E-06 Toluene 1.39E-05 6.09E-05 VOC 3.06E-03 1.34E-02 Notes: 1. 2.Annual emissions were conservatively based on continuous operation for 8,760 hr/yr. Table 7 Clearfield, Utah Northrop Grumman Systems Corp. IR&D Oven Emissions - 2023 Air Permitting Emission rates based on a 15-minute exposure test sample. Short-term and annual emissions were estimated using a fan maximum rated flow rate of 310 acfm. 7 of 14 Confidential DRAFT Emission Factor1 Emission Rate2 Emissions2 lb/MMcf lb/yr tpy PM10 (total)7.6 64 0.032 PM2.5 (total)7.6 64 0.032 SO2 0.60 5.0 0.003 NOx 100 839.1 0.420 VOC 5.5 46.1 0.023 CO 84 704.8 0.352 Carbon Dioxide 120,000 1,006,897 0,503 NH3 (Utah)3.2 27 0.013 Notes: 1. 2. Hourly emissions are based on operation of the 1 MMBtu/hr natural gas-fired oven at full capacity and assuming a fuel heat content of 1044 Btu/scf. Annual emissions were calculated assuming 8760 hrs/yr of operation. Emission factors from AP-42, Section 1.4 Natural Gas Combustion, emission factors are for an uncontrolled boiler <100 MMBtu/hr. Table 8 O-52 Oven CAP Emissions - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah Pollutant 8 of 14 Confidential DRAFT Emission Factor Emission Rate Potential to Emit lb/MMcf lb/yr tpy Lead 5.0E-04 0.0042 2.10E-06 N2O (Uncontrolled)2.2 18 9.23E-03 SO2 0.60 5.03 2.52E-03 TOC 11 92.30 4.61E-02 Methane 2.3 19.30 9.65E-03 VOC 5.5 46.15 2.31E-02 2-Methylnaphthalene 2.4E-05 0.0002 1.01E-07 Benzene 0.0021 0.02 8.81E-06 Butane 2.1 17.62 8.81E-03 Dichlorobenzene 0.0012 0.01 5.03E-06 Ethane 3.1 26.01 1.30E-02 Fluoranthene 3.0E-06 0.00003 1.26E-08 Fluorene 2.8E-06 0.00002 1.17E-08 Formaldeyde 0.075 0.63 3.15E-04 Hexane 1.8 15.10 7.55E-03 Naphthalene 6.1E-04 0.0051 2.56E-06 Pentane 2.6 21.82 1.09E-02 Phenanathrene 1.7E-05 0.0001 7.13E-08 Propane 1.6 13.4 6.71E-03 Pyrene 5.0E-06 0.00004 2.10E-08 Toluene 0.0034 0.029 1.43E-05 Arsenic 2.0E-04 0.002 8.39E-07 Barium 0.0044 0.037 1.85E-05 Cadmium 0.0011 0.009 4.61E-06 Chromium 0.0014 0.0117 5.87E-06 Cobalt 8.4E-05 0.0007 3.52E-07 Copper 8.5E-04 0.007 3.57E-06 Manganese 3.8E-04 0.003 1.59E-06 Mercury 2.6E-04 0.002 1.09E-06 Molybdenum 0.0011 0.009 4.61E-06 Nickel 0.0021 0.02 8.81E-06 Vanadium 0.0023 0.02 9.65E-06 Zinc 0.029 0.24 1.22E-04 Notes: 1. 2. Abbreviations: HAP - hazardous air pollutant PM - particulate matter hr - hours SO2 - sulfur dioxide lb - pounds TOC - total organic compounds MMBtu - million British thermal units tpy - tons per year MMcf - million cubic feet VOC - volatile organic compounds N2O - nitrous oxide yr - years Emission factors from AP-42, Section 1.4 Natural Gas Combustion, emission factors are for an uncontrolled boiler <100 MMBtu/hr. Hourly emissions are based on operation of the 1 MMBtu/hr natural gas-fired oven at full capacity and assuming a fuel heat content of 1044 Btu/scf. Annual emissions were calculated assuming 8760 hrs/yr of operation. Pollutant Table 9 O-52 Oven HAP Emissions - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah 9 of 14 Confidential DRAFT HAP Content HAP Content HAP Content Units (lb/gal)(Vol %)(gal/yr)(lb/yr)(tpy)(%)(lb/yr)(tpy)(%)(lb/yr)(tpy)(%)(lb/yr)(tpy)(%)(lb/yr)(tpy)(lb/yr)(tpy) 03W127A Catalyst 8.0 0.6 182.5 808.7 0.4 4%64.3 0.032 0%0.0 0.0 48%701.8 0.35 45%652.4 0.3 5.71 0.003 03W127 Base 13.0 0.2 182.5 408.3 0.2 1%23.8 0.012 0%0.0 0.0 0%0.0 0.0 82%1956.1 1.0 17.12 0.01 020GN084 12.0 0.3 273.8 973.2 0.5 1%32.9 0.016 2%79.0 0.039 0%0.0 0.0 52%1710.7 0.9 14.97 0.01 020GN084 Catalyst 9.0 0.2 91.3 144.7 0.1 2%16.4 0.008 0%0.0 0.0 0%0.0 0.0 81%668.7 0.3 5.85 0.003 Contego 10.0 0.0 4015.0 0.3 0.0 0%0.0 0.0 0%0.0 0.0 0%0.0 0.0 60%24123.7 12.1 211.08 0.11 Total (tpy)1.2 0.1 0.04 0.4 14.6 0.13 Notes: 1. 2. 3 HVLP transfer efficiency is 65%, fabric filter efficiency is 97.5%, and it is assumed that all PM emissions are PM2.5. -- Paint Methyl Isobutyl Ketone1 Formaldehyde1 Hexamethylene Diisocyanate1VOC Emissions1 HAP Emissions Density VOC content Usage VOC and HAP emissions assume all VOC or HAP content is emitted. Annual emissions were calculated assuming 8760 hrs/yr of operation and maximum paint usage. Table 10 Spray Booth Emissions - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah -- HAP Emissions HAP Emissions % Solids PM Emissions2 (uncontrolled) PM Emissions2 (controlled) -------- 10 of 14 Confidential DRAFT Emission Factor Emission Rate Potential to Emit lb/lb rubber lb/yr TPY Total VOC 1.8E-03 9.8 4.9E-03 Total HAPs 5.1E-04 2.8 1.4E-03 1,1,1-Trichloroethane 4.2E-06 0.023 1.2E-05 1,3-Butadiene 7.5E-06 0.042 2.1E-05 2-Butanone 3.0E-06 0.017 8.4E-06 Acetaldehyde 7.6E-06 0.043 2.1E-05 Acetophenone 4.4E-04 2.5 1.2E-03 bis(2-Ethylhexyl)phthalate 2.6E-06 0.015 7.3E-06 Carbon Disulfide 4.2E-06 0.023 1.2E-05 Cumene 2.8E-06 0.015 7.7E-06 Di-n-butylphthalate 7.2E-06 0.040 2.0E-05 Dimethylphthalate 6.7E-08 3.8E-04 1.9E-07 Hexachlorobutadiene 3.9E-07 2.2E-03 1.1E-06 Hexane 1.6E-05 0.092 4.6E-05 Methylene Chloride 1.8E-06 0.010 5.1E-06 Naphthalene 4.0E-06 0.023 1.1E-05 Phenol 1.3E-06 7.16E-03 3.6E-06 Toluene 2.7E-06 0.015 7.6E-06 Notes: 1. 2. Annual emissions were calculated assuming maximum production of 11 shipsets per year, with 913 ft rubber per shipset and 167 lb per 300 ft rubber. Table 11 Receiving Hood Exhaust - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah Pollutant Emission factors from AP-42, Section 4.12 Manufacture of Rubber Productions (draft version), emission factors are for curing and cooling processes. 11 of 14 Confidential DRAFT Pollutant Emission Factor1,2 (lb/106 scf) Emission Rate (lb/hr) Potential to Emit3 (tpy) NOx 100 -8.2E-03 -3.6E-02 CO 84 -6.9E-03 -3.0E-02 PM (total)7.6 -6.3E-04 -2.7E-03 SO2 0.6 -4.9E-05 -2.2E-04 VOC 5.5 -4.5E-04 -2.0E-03 NH3 (Utah)3.2 -2.6E-04 -1.2E-03 CO2 120,000 -9.9E+00 -43.3 CH4 2.3 -1.9E-04 -8.3E-04 N2O (uncontrolled)2.2 -1.8E-04 -7.9E-04 Notes: 1. 2. 3. Short-term emissions are based on operation of the 0.084 MMBtu/hr burner at full capacity. Annual emissions were calculated assuming 8760 hrs/yr of operation. Table 12 Removed Hot Room CAP and GHG Emissions - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah Emission factors from AP-42 Section 1.4: Natural Gas Combustion. Table 1.4-1, NOx and CO emission factors for uncontrolled small units (<100 MMBtu/hr). Table 1.4-2, all other pollutants except NH3. https://www.epa.gov/sites/default/files/2020- 09/documents/1.4 natural gas combustion.pdf. NH3 emission factor from EPA, Development and Selection of Ammonia Emission Factors. https://www3.epa.gov/ttnchie1/old/efdocs/ammonia.pdf. 12 of 14 Confidential DRAFT Pollutant Emission Factor1,2 (lb/106 scf) Emission Rate (lb/hr) Potential to Emit3 (tpy) Arsenic 2.0E-04 -1.6E-08 -7.2E-08 Benzene 2.1E-03 -1.7E-07 -7.6E-07 Beryllium 1.2E-05 -9.9E-10 -4.3E-09 Cadmium 1.1E-03 -9.1E-08 -4.0E-07 Chromium 1.4E-03 -1.2E-07 -5.0E-07 Cobalt 8.4E-05 -6.9E-09 -3.0E-08 Formaldehyde 7.5E-02 -6.2E-06 -2.7E-05 Hexane 1.8E+00 -1.5E-04 -6.5E-04 Lead 5.0E-04 -4.1E-08 -1.8E-07 Manganese 3.8E-04 -3.1E-08 -1.4E-07 Mercury 2.6E-04 -2.1E-08 -9.4E-08 Naphthalene 6.1E-04 -5.0E-08 -2.2E-07 Nickel 2.1E-03 -1.7E-07 -7.6E-07 Polycyclic Organic Matter 8.8E-05 -7.3E-09 -3.2E-08 Selenium 2.4E-05 -2.0E-09 -8.7E-09 Toluene 3.4E-03 -2.8E-07 -1.2E-06 Notes: 1. 2. 3. HAPs determined using EPA's Initial List of Hazardous Air Pollutants with Modifications. https://www.epa.gov/haps/initial-list-hazardous-air-pollutants-modifications. Short-term emissions are based on operation of the 0.084 MMBtu/hr burner at full capacity. Annual emissions were calculated assuming 8760 hrs/yr of operation. Table 13 Removed Hot Room HAP Emissions - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah Emission factors from AP-42 Section 1.4: Natural Gas Combustion. https://www.epa.gov/sites/default/files/2020-09/documents/1.4_natural_gas_combustion.pdf. 13 of 14 Confidential DRAFT Emission Factor1 Emission Rate Potential to Emit gr/scf lb/yr tpy PM10 (total)0.016 -843 -0.42 PM2.5 (total)0.016 -843 -0.42 SO2 ------ NOx ------ VOC ------ CO ------ NH3 (Utah)------ Notes: 1. 2. Grain loading rate listed in NGSC's 2022 emissions inventory. Short-term emissions are based on operation of the 702 scfm baghouse at full capacity. Annual emissions were calculated assuming 8760 hrs/yr of operation. Table 14 DC-28 Dust Collector CAP Emissions - 2023 Air Permitting Northrop Grumman Systems Corp. Clearfield, Utah Pollutant 14 of 14 Confidential Process Flow Diagram –Composites Manufacturing Inspect, Package & Ship Physical dimensioning equipment Ultrasonic inspection equipment Fabrication Forming machines Fiber placement machines Winding machines Raw Material Receipt & Storage Chemical & physical testing Freezers Resins Ceramics Carbon fiber Prepreg tow, tape, cloth Adhesives & Sealants Solvents, Paints & Primers Solid waste Nitrogen (to atmosphere) Nat. gas combustion products Vented off-gassing products PM Emissions (Cooling towers) Curing Autoclaves Ovens Kilns Plastic, breather cloth Nitrogen Natural gas Tool Preparation Ovens Ventilation booths Forms, molds & mandrels Release agent Cleaning solvents (IPA, acetone) Natural gas Solid waste VOC/HAP emissions Nat. gas combustion products Finishing Machining centers Spray booth Thermal Spray Solid waste VOC/HAP emissions PM Emissions Paints & primers Sealants Adhesives Solvents Metal Coil Material Preparation Pattern cutters Material prep machines Slitters Ovens Resin mixers Solid waste VOC emissions Nat. gas combustion products Cleaning solvents (IPA, acetone) Natural gas Packing materials Solid waste Solid waste CO2 emissions Form 2 Company Information/Notice of Intent (NOI) Utah Division of Air Quality New Source Review Section Date 11/21/2023 Application for: Initial Approval Order Approval Order Modification General Owner and Source Information 1 .Company name and mailing address: 2. Company** contact for environmental matters: Northrop Grumman Systems Corp. Jeff Schmidt PD Box 160433 Phone no.: ((801) 774-4171 Clearfield, UT 84016-0433 Email:j .schmidtngc.com t-rnone No.: ((iU1)) b-E3 141 Fax No ( ) Company contact only; consultant or independent contractor contact in formation 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: Freeport Center 14th St. UTM: 12 Clearfield, UT 84016 X: 414,000m y 4,550,000 m Phone no.: Faxno.: 5. The Source is located in:D avis County ______________________________________ 6. Standard Industrial Classification Code (SIC) a728_ ______________________ 7. If request for modification, AO# to be modified: DAQE AN1 01520028-22 DATED: 8. Brief (50 words or less) description of process. Northrop Grumman Systems Corp. (NGSC) manufactures aerospace composite structures at their Freeport Center plant. NGSC manufactures composite components for commercial and defense contractors in the aerospace industry. This AO modification would update the equipment on the permit to add and remove some emissions-generating units. Electronic NOl 9. A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black (jlblack@utah.gov) or Alan Humpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal Electronic Copy Submittal Both Authorization/Signature I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on rea,onable inquiry made byme/and to the best of my knowledge and belief. Sianature: EH&S Engineer / I Telephone Number: I Date: 12/14/2023 II II Jeff Schmidt I ((80))7744171 I II I Email: I II Name (Type or print) I I " I j.schmidtngc.com I II 1 of 1 Form 1 Date __________________ Notice of Intent (NOI) Application Checklist Company __________________ 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  1.Detailed description of the project and source process 2.Discussion of fuels, raw materials, and products consumed/produced 3.Description of equipment used in the process and operating schedule 4.Description of changes to the process, production rates, etc. 5.Site plan of source with building dimensions, stack parameters, etc. 6.Best Available Control Technology (BACT) Analysis [R307-401-8] A.BACT analysis for all new and modified equipment 7.Emissions Related Information: [R307-401-2(b)] A.Emission calculations for each new/modified unit and site-wide (Include PM10, PM2.5, NOx, SO2, CO, VOCs, HAPs, and GHGs) B.References/assumptions, SDS, for each calculation and pollutant C.All speciated HAP emissions (list in lbs/hr) 8.Emissions Impact Analysis – Approved Modeling Protocol [R307-410] A.Composition and physical characteristics of effluent (emission rates, temperature, volume, pollutant types and concentrations) 9.Nonattainment/Maintenance Areas – Major NSR/Minor (offsetting only) [R307-403] A.NAAQS demonstration, Lowest Achievable Emission Rate, Offset requirements B.Alternative site analysis, Major source ownership compliance certification 10.Major Sources in Attainment or Unclassified Areas (PSD) [R307-405, R307-406] B.Visibility impact analysis, Class I area impact 11.Signature on Application 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. 1 of 1 Form 2 Date ____________ Company Information/Notice of Intent (NOI) Utah Division of Air Quality New Source Review Section Application for: □ Initial Approval Order □Approval Order Modification General Owner and Source Information 1.Company name and mailing address: ___________________________ ____________________________ ____________________________Phone No.: ( ) Fax No.: ( ) 2.Company** contact for environmental matters: ____________________________ Phone no.: ( ) Email: _______________________ ** 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 above):____________________________ ____________________________ ____________________________ Phone no.: ( ) Fax no.: ( ) 4.Source Property Universal Transverse Mercator coordinates (UTM), including System and Datum: UTM:_________________________ X:____________________________ Y:____________________________ 5.The Source is located in:__________________ County 6.Standard Industrial Classification Code (SIC) __ __ __ __ 7.If request for modification, AO# to be modified: DAQE #__________________ DATED: ____/____/____ 8.Brief (50 words or less) description of process. Electronic NOI 9.A complete and accurate electronic NOI submitted to DAQ Permitting Mangers Jon Black (jlblack@utah.gov) or Alan Humpherys (ahumpherys@utah.gov) can expedite review process. Please mark application type. Hard Copy Submittal Electronic Copy Submittal □ Both Authorization/Signature I hereby certify that the information and data submitted in and with this application is completely true, accurate and complete, based on reasonable inquiry made by me and to the best of my knowledge and belief. Signature: Title: _______________________________________ Name (Type or print) Telephone Number: ( ) Email: Date: Page 1 of 1 Form 3 Company____________________ Process Information Site________________________ Utah Division of Air Quality New Source Review Section Process Information - For New Permit ONLY 1.Name of process:2.End product of this process: 3.Process Description*: Operating Data 4.Maximum operating schedule: __________ hrs/day __________days/week __________weeks/year 5.Percent annual production by quarter: Winter ________ Spring _______ Summer ________ Fall _______ 6.Maximum Hourly production (indicate units.): _____________ 7.Maximum annual production (indicate units): ________________ 8.Type of operation: Continuous Batch Intermittent 9.If batch, indicate minutes per cycle ________ Minutes between cycles ________ 10. Materials and quantities used in process.* Material Maximum Annual Quantity (indicate units) 11.Process-Emitting Units with pollution control equipment* Emitting Unit(s) Capacity(s) Manufacture Date(s) *If additional space is required, please create a spreadsheet or Word processing document and attach to form. 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. Page 1 of 1 Company___________________________ Site _____________________________ Form 5 Emissions Information Criteria/GHGs/ HAP’s Utah Division of Air Quality New Source Review Section Potential to Emit* Criteria Pollutants & GHGs Criteria Pollutants Permitted Emissions (tons/yr) Emissions Increases (tons/yr) Proposed Emissions (tons/yr) PM10 Total PM10 Fugitive PM2.5 NOx SO2 CO VOC VOC Fugitive NH3 Greenhouse Gases CO2e CO2e CO2e CO2 CH4 N2O HFCs PFCs SF6 Total CO2e *Potential to emit to include pollution control equipment as defined by R307-401-2. Hazardous Air Pollutants** (**Defined in Section 112(b) of the Clean Air Act ) Hazardous Air Pollutant*** Permitted Emissions (tons/yr) Emission Increase (tons/yr) Proposed Emission (tons/yr) Emission Increase (lbs/hr) Total HAP *** Use additional sheets for pollutants if needed Permitted Emissions Proposed Emissions Emissions Increase tons/yr tons/yr tons/yr lbs/hr 1,1,1-Trichloroethane 9.5 0 9.5 0 1,1,2-Trichloroethane 2 0 2 0 1,3-Butadiene 0 Generic HAP 0 0 1,4-Dichlorobenzene(p)0 Generic HAP 0 0 2-(2-Butoxyethoxy)-Ethanol 2 0 2 0 2-Butanone 0 Generic HAP 0 0 Acetaldehyde 0 Generic HAP 0 0 Acetophenone 0 Generic HAP 0 0 Arsenic 0 Generic HAP 0 0 Benzene 0 Generic HAP 0 0 Beryllium 0 Generic HAP 0 0 bis(2-Ethylhexyl)phthalate 0 Generic HAP 0 0 Cadmium 0 Generic HAP 0 0 Carbon Disulfide 0 Generic HAP 0 0 Chloromethane 0 Generic HAP 0 0 Chromium 0.014 0 0.014 0 Cobalt 0 Generic HAP 0 0 Cumene 2 0 2 0 Dimethylphthalate 0 Generic HAP 0 0 Di-n-butylphthalate 0 Generic HAP 0 0 Ethyl Acrylate 2 0 2 0 Ethyl Benzene 2 0 2 0 Ethylene Glycol 2 0 2 0 Formaldehyde 0.5 0 0.5 0 Generic HAPs 1.2 0 1.2 0 Glycol Ethers 2 0 2 0 Hexachlorobutadiene 0 Generic HAP 0 0 Hexamethylene-1,6-Diisocyanate 0.007 0 0.007 0 Hexane 2 0 2 0 Hydrogen Fluoride (Hydrofluoric Acid)0.01 0 0.01 0 Lead 0 Generic HAP 0 0 Manganese 0 Generic HAP 0 0 Mercury 0 Generic HAP 0 0 Methanol 2 0 2 0 Methyl Isobutyl Ketone 2 0 2 0 Methyl Isocyanate 0.01 0 0.01 0 Methyl Methacrylate 0 0 0 0 Methylene Chloride (Dichloromethane)2 0 2 0 Methylenedianiline 0.01 0 0.01 0 Methylene Diphenyl Diisocyanate (MDI)0.01 0 0.01 0 Naphthalene 2 0 2 0 Nickel 0.02 0 0.02 0 Phenol 2 0 2 0 Polycyclic Organic Matter 0 Generic HAP 0 0 Selenium 0 Generic HAP 0 0 Styrene 0 0 0 0 Tetrachloroethylene (Perchloroethylene)2 0 2 0 Toluene 2 0 2 0 Trichloroethylene 2 0 2 0 Xylenes (Isomers and Mixture)2 0 2 0 TOTAL HAP 19.00 0.00 19.00 0 HAP Emissions Increase Docuinonl Ddlo: 02/28/2018 DAQ-2018-00226 ~7\