PERMIT TO OPERAT E Number 023 2

Transcription

1 1/15/ 99 FRI 9 :56 FAX VENTURA CTY APC D IQj 3 HDMSP3359 Ventura County 669 County Square Drive tel 85/ Richard H. Baldwin Air Pollutio n Ventura, California 933 fox 85/ AirPoll uffon Control Officer Control District PERMIT TO OPERAT E Number 23 2 This Permit Has Been Issued To The Following : Company Name / Address: Facility Name / Address : Boeing N. American- Rocketdyne Rocketdyne Division P.O. Box 7922 MS : DB52 Rocket Engine Testing Canoga Park, CA Simi Valley, CA Permission Is Hereby Granted To Operate The Following : Alfa Test Area consisting of : 2 - Rocket Engine Test Stands (Nos. Alfa-l and Alfa-3) 1 - Gaseous Nitrogen (GN2) Flushing Syste m Bravo Test Area consisting of : 2 - Rocket Engine Test Stands ( Nos. Bravo- 1 and Bravo-2) Coca Test Area consisting of : 1 - Rocket Engine Test Stand (Coca ) At The Advanced Propulsion Test Facility ( APTF) : Rocket Engine Test Stands : Pit 1 Test Stands : LIMA A, B, C, and D ; MIKE and NAN Pit 2 Test Stand : PETE R PETER Stand : 2 Afterburners NAN Stand : 1 Afterburne r 5 - Hydrogen Flare Stacks, At The Following Locations : Tank No Hilltop High Pressure Hydrogen Storage Tank No. V-65 Hydrogen Storage Tank No. V-122, 145 MMBTU/Hr NAN Stand Liquid Hydrogen Exhaust, 145 MMBTU/H r Systems Test Laboratory No. 4 (STL-4 ) consisting of : 7 - Rocket Engine Test Positions, using monomethyl hydrazine ( MMH), hydrogen, oxygen, nitrogen tetroxide (NTO), nitrogen oxide, inhibited red fuming nitric acid ( IRFNA ), hydrogen peroxide, and JP-8 as propellants (Nos. 24A, 24B, 29A, 29B, 35, 37A, and 37B ) 2 - Hyperflow Steam Ejection Systems, using alcohol and liquid oxygen ( Nos. 29. (A and B ) and 37 ( A and B) ) 1-7 ft. diameter, 2 ft. height Scrubber containing water, for the control of monomethyl hydrazine (MMH) from the propellant loading syste m Page 1 of

2 HDMSP336 1/15/ 99 FRI 9 :57 FAX VENTURA CTY APC D 9 4 VCAPCD Permit to operate Number 232 Propellant Load Facility consisting of : 2-36 gallon Nitrogen Tetroxide (NTO) Storage Tanks with a Graham type 8 fume scrubbe r 1-32 gallon Monomethyl Hydrazine ( MMH) Storage Tank with a Graham type 8 fume scrubber At The CTL III-Hypergol Facility : Flushing Operations Using ROC Materials With VP Less Than or Equal to 25 mm Hg at 2 Degrees Celsiu s Solvent Cleaning at Various Locations ; consisting of : Non atomized solvent flow, dip, or flush method where pooling is prevented or drained, and all solvent runoff is collected in a manner that enables solvent recovery or disposal ; and Non conveyorized degreasers which use unnheated solvent and which have a liquid surface area of less than one square foot ; and wipe Cleaning operation s 75 Cubic Yards Per Hour Soil Screening Operation, Near Building 372, Including the Use of a Kolman Athey Super Screen II, and Engines With a Maximum Rating of Less Than. 5 Brake Horsepowe r This Permit Has Been Issued Subject To The Following Conditions : 1. Permitted Emissions : Reactive Organic Compounds Nitrogen Oxides Particulate Matter Sulfur Oxides Carbon Monoxide 1,1,1-trichloroethane Tons/Year Pounds/Hou r , , , Permitted Emissions Limits : ROCKET ENGINE TESTING AND ADVANCED PROPULSION TEST FACILITY : Permitted emissions from rocket engine testing conducted at Alfa/ Bravo, Coca, STL-4, APTF Pit 1 (LIMA At B, C. and D ; MIKE and NAN), APTF Pit 2 (PETER ), NAN Stand Afterburner, PETER Stand Afterburners, and the five (5) hydrogen flare stacks at the APTF shall not exceed : ROC NOx PM SOx CO Tons/ Year Pounds/Hour 25. 1, , Page 2 of

3 1/15/ 99 FRI 9 : 57 FAX VENTURA CTY APCD 1 5 HDMSP3361 VCAPCD Permit to operate Number 232 The ROC permitted emissions include residual fuel emissions from the gaseous nitrogen flushing system. Permittee may perform any combination of rocket engine tests (including engine testing using 1,1 gallons per year of denatured ethanol fuel), denatured. ethanol blowdowns, and gaseous nitrogen flushing operations where the total emissions from testing do not exceed the annual or hourly emission limits listed above. HYPERFLOW OPERATIONS : Permitted emissions from hyperflow operations conducted at STL-4 shall not exceed : ROC NOx PM SOx CO Tons/Year Pounds / Hour 1,47. 8,13. Permittee may perform any combination of hyperflow operations wher e the total emissions from hyperflow operations do not exceed the annua l or hourly emission limits listed above. NITROGEN TETROXIDE ( NTO) VENTING OPERATIONS : Permitted emissions from the STL-4 nitrogen tetroxide operations shall not exceed : ( NTO) ventin g ROC NOx PM SOx CO Tons / Year 8.78 Pounds/ Hour 32. Permittee may perform any combination of NTO and MMH ventings where the total emissions from these operations do not exceed the annual or hourly emission limits listed above. NTO venting emissions at STL - 4 include associated venting or nitrogen purging of NTO from tanks and lines. PROPELLANT LOAD FACILITY : The permitted emissions from the propellant load facility shall not exceed : ROC NOx PM SO x CO Tons/Year.14 Pounds/Hour In addition, NTO propellant loading shall not exceed 86.4 ventings per year, MMH propellant loading shall not exceed 18 ventings per year, and MMH tank venting shall not exceed 17 ventings per year. FLUSHING OPERATIONS AT THE CTL III-HYPERGOL FACILITY : Page 3 of

4 1/15/ 99 FRI 9 : 58 FAX VENTURA CTY APCD 916" HDMSP3362 VCAPCD Permit to operate Number 232 Valid October 1, 1998 to September 3, Permitted emissions from flushing operations at the.ctl III-Hypergol facility shall not exceed a net loss ( used minu s recovered ) of 2 poun d s of ROC per year and. 1 pounds of ROC per hour. WIPE CLEANING OPERATIONS : Permitted emissions from wipe cleaning operations conducted throughout th e facility shall not exceed : ROC NOx PM Sox C o Tons / Year. 46 Pounds / Hour.44 In addition, usage of ROC-containing materials is limited to 139 gallons per year ( prior to dilution with water ) that result in ROC emissions not exceeding pounds per year for wipe cleaning purposes ; and 25 gallons per year of 1,1,1-trichloroethane ( TCA) with no more than 5% by weight ROC additives / stabilizers for wipe cleaning purposes. ( Please note : neither the gallons per year limit nor the pounds of ROC per year limit shall be exceeded ). Material usage is defined as material utilized minus material that is recycled or properly disposed. ADDITIONAL CLEANING OPERATIONS ( NOT EXCLUDING WIPE CLEANING THAT IS NOT ASSOCIATED WITH APCD RULES 74.2,74. 12, 74.13, NOR RULE 74.2) : No more than 42 gallons per year shall be used for : Cleaning not associated with APCD Rules 74.2, , 74.13, nor 74.2, and using a non-atomized solvent flow, dip, wipe, or flush method where pooling is prevented or drained, and all solvent runoff is collected in a manner that enables solvent recovery or disposal. The solvent must comply with the requirements of APCD Rule , "Surface Cleaning and Degreasing" ; o r Non-conveyorized degreasers which use unheated solvent and which have a liquid surface area of less than one square foot, and which meet all applicable requirements of APCD Rule 74.6 and APCD Rule , "Cold Cleaning Operations". SOIL SCREENING : No more than 5, cubic yards per year of soil shall be handled. Usage of acetone is not limited by this permit and is exempt from permit and recordkeeping requirements. This is due to the re-classification of acetone as an exempt ROC due to low reactivity, and to the re-classification of acetone as a non-hazardous air pollutant. Note that cleaning products may be used for janitorial services and for routine janitorial maintenance, including graffiti removal, but the quantity used does not apply towards this limit since these materials are exempt from permit requirements ( APCD Rule 23.F.8). Page 4 of

5 1/15 / 99 FRI 9 : 59 FAX VENTURA CTY AFC D 1 7 HDMSP3363 VCAPCD Permit to operate Number 232 issued To Rocketdyne Division is Also note that cleaning activities using cleaning agents that contain two percent or less organic solvents, as applied by weight are not limited by this permit and are exempt from permit requirements and recordkeeping requirements ( Rule 23.F.1.a and Rule 74.6.C.l.a). hydrogen, Nonrefillable aerosol cleaning. products are also exempt from permit requirements and recordkeeping requirements ( Rule 23.F.1.b). The term "ROC " refers to Reactive Organic Compounds, as defined in APCD Rule 2. More stringent ROC limits may be applicable to materials specified in this condition, as described in condition Nos. 4., 5, and 6. In order to demonstrate compliance with the emissions or usage limits specified above, permittee shall update emission or usage information each day a change occurs as required by'condition No. 12. These daily calculations shall be combined into monthly summaries. The monthly summaries shall be summed for the previous 12 consecutive months. Totals for the previous 12 consecutive months exceeding the annual limits for that specific operation, facility, or usage, as shown above, shall be considered a violation of this condition. 3. Propellant use at the STL-4 facility shall be restricted to nitrogen tetroxide, nitrogen tetroxide with a maximum of 25% nitrogen oxide, oxygen, inhibited red fuming nitric acid, monomethyl hydrazine, hydrogen peroxide, and JP Any wipe cleaning operation performed on aerospace components shall comply with APCD Rule 74.13, "Aerospace Assembly and Component Manufacturing". According to Subsection B.2 of Rule 74.13, no solvent shall be used for surface cleaning or clean-up unless the solvent contains less than 2 grams of ROC per liter of material, as applied, or the ROC composite partial pressure of the solvent is less than or equal to 25 mm Hg at a temperature of 2 degrees Celsius. Note that isopropyl alcohol (IPA) diluted with water at a ratio of 9 parts IPA : 1 part water ( or 9 :>l) complies with the 25 mm Hg vapor pressure requirement. 5. The flushing operations shall comply with all applicable requirements of VCAPCD Rule 74.13, ""Aerospace Assembly and Component Manufacturing". Specifically, the ROC composite partial pressure of the solvent used for flushing operations shall be no greater than 25 mm Hg at 2 degrees Celsius. 6. Cleaning operations not associated with aerospace assembly and component manufacturing operations shall comply with all applicable provisions of APCD Rule 74.6, "Surface Cleaning and Degreasing ", including, but not limited to, the following material requirements : a) Any materials used for repair or maintenance cleaning shall have an ROC composite partial pressure no greater than 2 mm Hg at a temperature of 2 degrees Celsius and shall have an ROC content no greater than 9 grams per liter of material (Rule ). Page 5 of

6 1/15 / 99 FRI 9 : 59 FAX VENTURA CTY APCD 8 8 HDMSP3364 VCAPCD Permit to operate Number 232 Repair cleaning means it is carried out during a repair process. Maintenance cleaning is carried out to keep tools, machinery, molds, forms, jigs, equipment, or general work areas in clean and good operational condition. b) Any materials used for cleanup, including cleanup of application equipment, shall have an ROC composite partial pressure no greater than 35 mm Hg at 2 degrees Celsius and shall have an ROC content no greater than 95 grams per liter of material ( Rule ). Cleanup is defined as the removal of uncured coating, adhesive or ink from any surface, including coating application equipment, oversprayed surfaces, and hands. Application equipment is used to clean inks, or adhesives, and includes but is not limited to : spray guns, rollers, brushes, and printing presses. c) Any materials used for manufacturing cleaning or surface preparation shall have an ROC content no greater than 7 grams per liter of material ( Rule 74.6.B.1). Manufacturing cleaning is the cleaning of parts or components in a process of making goods or articles by hand or by machinery from those parts or components. Surface preparation is the removal of contaminants prior to coating, adhesive, or ink application. d) Items a) and c) do not apply to the cleaning of electronic components or medical devices. For the cleaning of electronic components or medical devices, the solvent shall have an ROC content of 9 grams per liter or less and shall have an ROC composite partial pressure no greater than 33 mm Hg at 2 degrees Celsius. The use of-isopropyl alcohol shall be deemed in compliance with this requirement (Rule 74.6.C. 3.a). For a definition of electronic components or medical devices, refer to Subsections G.14 and G.29 of Rule e) Items a ), b), and c) do not apply to : Cleaning activities using cleaning agents that contain two percent or less organic solvent, as applied by weight (Rule 74.6.C.l.a) ; Cleaning activities using solvents which are purchased in, and applied from, manufacturer - or distributor- labeled containers of one liter or less in volume, including aerosol products (Rule 74.6.C.l.b) ; and Janitorial cleaning, including graffiti (Rule 74.6.C.l.c ) removal 7. Cleaning operations not associated with aersospace assembly and component manufacturing operations shall comply with all applicable provisions of APCD Rule 74.6, "Surface Cleaning and Degreasing ". Accordingly, no person Page 6 of

7 1/15 / 99 FRI 1 : FAX VENTURA CTY APCD t 9 HDMSP3365 VCAPCD Permit to Operate Number 232 Issued To Rocketdyne Division shall perform solvent cleaning unless one of the following cleaning devices or methods is used ( Rule 74.6.B.2)! a) Wipe cleaning where solvent is dispensed to wipe cleaning materials from containers that are kept closed to prevent evaporation, except while dispensing solvent or replenishing the solvent supply ; b) Application of solvent from a hand-held spray bottle, squirt bottle or other closed container with a capacity of one liter or less ; C) Non- atomized solvent flow, dip, or flush method where pooling is prevented or drained, and all solvent runoff is collected in a manner that enables solvent recovery or disposal. The collection system shall be kept closed to prevent evaporation except while collecting solvent runoff or emptying the collection system ; d) A properly used enclosed gun washer or low emission spray gun cleaner. This condition does not apply to : cleaning activities using cleaning agents that contain two percent or less organic solvent, as applied by weight ; and janitorial cleaning, including graffiti removal. 8. This permit authorizes the use of soil screening equipment consisting of a Kolman-Athey Super Screen II for the conveying, and screening of soil potentially containing unexploded ordnance at the Santa Susanna Field Laboratory in Happy Valley, near Building 372 : The Super Screen II consists of up to four conveyors, one hopper, and one double deck screen. 9. The soil screening equipment shall be equipped with water spray bars or other equivalent dust control equipment. Dust control equipment shall be properly maintained and operated during all operating periods. The dust control equipment shall be repaired or replaced as necessary. 1. Access roads in the general area of the soil handling operation shall be watered or otherwise treated as necessary to prevent dust generated by vehicle traffic from exceeding the emission standards of APCD Rule 5, Opacity, and APCD Rule 51, Nuisance. 11. In order to comply with APCD Rule 5, Opacity, the permittee shall control fugitive emissions from the soil handling operations as necessary in order to prevent visible emissions from exceeding 2% opacity for more than 3 minutes in any one hour. 12. Permittee shall maintain daily records and prepare monthly summaries of the following. The records and summaries shall be maintained for at least two years and be made available to the APCD upon request. Rocket Engine Testing and Advanced Propulsion Test Facility : The date, time, location, hardware tested, test duration ( in seconds), fuel used, amount of denatured ethanol fuel used, emission factor, and the emissions based on actual engine testing operations. The date, Page 7 of 9 O

8 1/15 / 99 FRI 1 : 1 FAX VENTURA CTY APCD IQj 1 HDMSP3366 VCAPCD Permit to Operate Number 232 time, location, number of denatured ethanol fuel blowdowns, amount of denatured ethanol used for blowdowns, emission factor, and the emissions based on actual denatured ethanol blowdown operations. The date, time, location, hardware flushed, emission factor, and the emissions based on actual gaseous nitrogen engine flushing operations. Hydrogen testing and flaring records and monthly summaries showing the amount of liquid hydrogen delivered to Tank Nos. V-122 and V-65 ; the amount of gaseous hydrogen received from other sources, including the facilities pipeline system, and destroyed by the flares ; and, a n estimate of liquid hydrogen remaining in Tank Nos. V-122 and V-65. Rocketdyne shall summarize the above information and calculate the total emissions resulting from operation of the rocket engine test stands and the flares for the previous month, and calculate the total emissions for rocket engine testing, including the hydrogen flares. Hyperf low Operations : The date, time, location, and operation duration ( in seconds ) for each test of the hyperflow system, emission factor, and the emissions. STL-4 Nitrogen Tetroxide Venting operations : The permittee shall determine the total emissions from NTO venting operations at STL-4 and the amount of NTO, in pounds, aspirated at STL-4. Propellant Load Facility : The permittee shall record the number of ventings and calculate the emissions during NTO loading, MMH loading, and MMH tank venting. Flushing Operations At The CTL III-Hypergol Facility : Permittee shall maintain records of the net amount of flushing solvent used ( used minus recovered), the resulting emissions, and the composite vapor pressure of the solvent used. Wipe Cleaning Operations : The permittee shall maintain a current material list showing each ROC-containing material used in wipe cleaning activities. The list shall summarize the following information for wipe cleaning operations : a) Material name and manufacturer ' s description ; b) The ROC content ( and ROC composite partial pressure, if applicable) of the material ; C) If the material is a mix of materials blended by the operator, record the mix ratio ; and Page 8 of

9 1/1 5 / 99 FRI 1 :1 FAX VENTURA CTY APCD E'1 1 HDMSP3367 VCAPCD Permit to Operate Number 232 Issued To Rocketdyne Division d) All intended uses of the material at the facility ; If cleaning is not associated with aerospace assembly and component manufacturing, use of the material shall be classified as follows for Rule 74.6 : repair or maintenance cleaning ; cleanup, including application equipment cleaning ; manufacturing or surface preparation cleaning ; or material used pursuant to an exemption in Section C of the rule ( specify the exemption claimed). If cleaning is associated with aerospace assembly and component manufacturing, specify the type of use and corresponding Subsection in Rule that applies. On a monthly basis, the permittee shall record the net quantity of each ROC-containing material used ( usage minus recycle and disposal) for wipe cleaning and the corresponding emissions. Cold Cleaners : Soil The permittee shall maintain on a monthly basis or shorter, for each cold cleaner, the amount of solvent each time make -up solvent is added. Manufacturer ' s documentation shall also be maintained which provides all data necessary to determine whether the solvent is a "low volatility" or "high volatility" solvent under the Rule 74.6 definition. screening : The permittee shall maintain monthly records of the volume, in cubic yards, of soil handled. Within ten days after receipt of this permit, the applicant may petition the Hearing Board to review any new or modified condition on the permit ( Rule 22). This permit, or a copy, shall be posted reasonably close to the subject equipment and shall be readily accessible to inspection personnel ( Rule 19). This permit is not transferable from one location to another unless the equipment is specifically listed as being portable ( Rule 2). In reliance upon the statement of the applicant that operation of the equipment described herein shall meet the requirements as specified in the Rules and Regulations of the Air Pollution Control District, permission is hereby granted to operate ; provided, however, the permission granted hereby shall not be construed to permit said equipment to operate in violation of any applicable State or Federal emission standard or Rules and Regulations of the District. For : Karl E. Krause, Manager Richard H. Baldwin Engineering Division Air pollution Control Office r Page 9 of