1 - Monomethyl Hydrazine Propellant Loading System, with

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Air Pollution
Control District
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PERMIT TO OPERATE
Number 0023 2
Valid October 1, 1999 to September 30, 2000
This Permit Has Been Issued To The Following :
Company Name / Address :
Facility Name / Address :
The Boeing Company Santa Susana Field Laboratory
P .O . Box 7922 MS : DB52 Rocket Engine Testing
Canoga Park, CA 91309-7922 Simi Valley, CA 93065
Permission Is Hereby Granted To Operate The Following :
Alfa Test Area
2 - Rocket Engine Test Stands (Nos . Alfa-1 and Alfa-3)
1 - Gaseous Nitrogen (GN2) Flushing Syste m
Bravo Test Are a
2 - Rocket Engine Test Stands (Nos . Bravo-1 and Bravo-2)
Coca Test Area
1 - Rocket Engine Test Stand (Coca)
Advanced Propulsion Test Facility (APTF )
6 - Rocket Engine Test Stands : Pit 1 Test Stands-LIMA A, B, C,
and D ; MIKE and NA N
1 - Rocket Engine Test Stand : Pit 2 Test Stand-PETER
2 - Afterburners : PETER Stand
1 - Afterburner : NAN Stand
5 - Hydrogen Flare Stacks, located at Tank No . 1156, Hillto p
High Pressure, Hydrogen Storage Tank No . V-650, Hydrogen Storage
Tank No . V-122 (145 MMBtu/hr), and NAN Stand Liquid Hydrogen
Exhaust (145 MMBtu/hr )
Systems Test Laboratory No . 4 (STL-4 )
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, 37A,
and 37 B
2 - Hyperflow Steam Ejections System , using alcohol and liquid
oxygen ( Nos . 29 (A and B) and 37 (A and B) )
1 - Monomethyl Hydrazine Propellant Loading System, with
emissions controlled by a 71 diameter, 201 high scrubber
containing water
Page 1
03/22/200 0
HDMSPOO131644
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
Propellant Load Facility
2 - 360 Gallon Nitrogen Tetroxide
Graham type 800 fume scrubber
( NTO) Storage Tanks with a
1 - 320 Gallon Monomethyl Hydrazine
Graham Type 800 fume scrubber
( MMH) Storage Tank with a
CTL-III Hypergol Facilit y
1 - Flushing System using ROC Materials with vapor pressure
less than or equal to 25 mm Hg at 20 degrees Celsiu s
Hydrogen Flaring operations, used in structural strength testing of
Delta IV rocket fuel tank s
1 - 610 MMBTU/hr Hydrogen Flare Stack, located at Vessel V-100
1 - 1955 MMBTU/hr Hydrogen Flare Stack, located at Coca IV Test
Stan d
Solvent Wipe Cleaning, flow cleaning, dip cleaning, flushing, and
unheated degreasers less than 1 square foo t
Soil Screening operatio n
1 - 75 Cubic Yards Per Hour Kolman Athey Super Screen II, Near
Building 372, Including the Use of Engines with a Maximum Rating
of Less than 50 Brake Horsepower
This Permit Has Been Issued Subject To The Following conditions :
1.
Permitted Emissions
Tons/Year
Reactive Organics
Nitrogen Oxides
Particulate Matter
62 .25
1,495 .7 8
62 .52
3,281 .0 9
2 .12
2 .76
838 .92
0 .13
Sulfur Oxides
Carbon Monoxide
1,1,1-Trichloroethane
Pounds/Hou r
92
113
31,179
0
.0 5
.0 0
.2 5
.1 3
2 . 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 A, 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 APT F
shall not exceed :
Tons/Year
Pounds/Hour
Page 2
ROC
1 .45
NO x
40 .63
PM
2 .10
Sax
2 .76
CO
505 .7 9
25 .00
1,369 .34
91 .00
113 .00
23,049 .2 5
03/22/200 0
H DMS POO131645
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
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 1,100 gallons per year of denatured
ethanol fuel and 1 , 100 gallons per year of methanol fuel),
denatured ethanol blowdowns and methanol 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
shall not exceed :
Tons / Year
Pounds / Hour
ROC
60 .07
1,470 . 00
NOx
0
0
PM
0
0
SOx
0
0
at STL-4
CO
333 .1 3
8,130 .0 0
Permittee may perform any combination of hyperflow operations
where the total emissions from hyperflow operations do not
exceed the annual or hourly emission limits liste d
above .
NITROGEN TETROXIDE
( NTO) VENTING OPERATIONS :
Permitted emissions from the STL-4 nitrogen tetroxide (NTO)
venting operations shall not exceed :
ROC
Tons / Year
0
Pounds / Hour
0
NOx
PM
SOx
8 .78
0
0
0
32 .00
0
0
0
Co
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
not exceed :
Tons / Year
Pounds/Hour
ROC
NOx
0
0 .08
0 .14
3 .23
PM
0
0
SOx
0
0
facility shall
CO
0
0
In addition , NTO propellant loading shall not exceed 86 .4
ventings per year , MMH propellant loading shall not exceed 108
ventings per year, and MMH tank venting shall not exceed 17 0
Page 3
03/22/200 0
H DMS POO131646
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
ventings per year .
HYDROGEN FLARING OPERATIONS :
No more than 580 , 464 pounds per year of liquid hydrogen used for
structural strength testing of Delta IV rocket fuel tanks shall be
flared .
All flaring shall take place in the 610 MMBTU / Hr Flare at
Vessel V-100 and the 1955 MMBTU/ Hr Flare at the Coca IV Test Stand .
FLUSHING OPERATIONS AT THE CTL III-HYPERGOL FACILITY :
Permitted emissions from flushing operations at the CTL
III-Hypergol facility shall not exceed a net loss ( used minus
recovered ) of 200 pounds of ROC per year and 0 .10 pounds of ROC per
hour .
WIPE CLEANING OPERATIONS :
Permitted emissions from wipe cleaning operations conducted
throughout the facility shall not exceed :
Tons / Year
Pounds / Hour
ROC
NOx
PM
SOx
0 .46
0
0
0
0 . 44
0
0
0
CO
0
0
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 916 .01 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 .20) :
No more than 42 gallons per year shall be used for :
Cleaning not associated with APCD Rules 74 .2, 74 . 12, 74 . 13, nor
74 .20, 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 74 .6 .B . 1, "Surface Cleaning and
Degreasing" ; or
Non-conveyorized degreasers which use unheated solvent and
which have a liquid surface area of less than one square foot ,
Page
4
03 / 22/200 0
H DMS POO131647
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
and which meet all applicable requirements of APCD Rule 74 .6
and APCD Rule 74 .6 .1, "Cold Cleaning Operations" .
SOIL SCREENING :
No more than 5,000 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) .
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 .10 .a and
Rule 74 .6 .C .1 .a) .
Nonrefillable aerosol cleaning products are also exempt from
permit requirements and recordkeeping requirements (Rule
23 .F .10 .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 . 6, 7, and 8 .
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 .
14 . 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 . For the purposes of this permit, rocket engine testing means the
testing of fully assembled rocket engines, partially assembled
rocket engines or rocket engine components . Rocket engine
components include but are not limited to gas generators, injectors
and pumps .
4 . The only liquid propellants that are permitted for use in rocket
engine testing are the following :
RP-1, JP-8, JP-10, ethanol,
methanol , hydrogen , monomethyl hydrazine , oxygen , hydroge n
Page
5
03 /22/200 0
H DMS POO131648
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
peroxide, nitrogen tetroxide with a maximum of 25% nitrogen oxide,
and inhibited red fuming nitric acid . No solid rocket engine
propellants may be used at the facility . This condition does not
limit the materials that may be used in the rocket engine ignitors
at the facility .
5 . The permittee has leased 16 .86 tons per year of NOx emission
reduction credits to offset 12 .97 tons per year of NOx emissions
from hydrogen flaring operations to be conducted in association
with testing of Delta IV rocket fuel tanks (Authority to Construct
No . 00232-310) . The term of the lease is January 5, 2000, to
January 4, 2001 . Therefore, on January 4, 2001, hydrogen flaring
operations conducted in association with testing of Delta IV rocket
fuel tanks shall terminate .
Prior to conducting flaring operations after January 4, 2001,
permittee shall submit an application pursuant to Rule 26 .4 .F .3
demonstrating that the lease for the emission reduction credits has
been extended or that permanent emission reduction credits for the
project have been obtained .
6 . 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 200 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 20 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 .
7 . 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 20 degrees Celsius .
8 . 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 shal l
have an ROC composite partial pressure no greater than 20 mm Hg
at a temperature of 20 degrees Celsius and shall have an ROC
content no greater than 900 grams per liter of material (Rule
74 .6 .B .1) .
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 .
Page 6
03/22/200 0
HDMSPOO131649
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
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 20 degrees Celsius and
shall have an ROC content no greater than 950 grams per liter of
material ( Rule 74 .6 .B .1) .
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 70 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 900 grams per liter or less and shall have an ROC
composite partial pressure no greater than 33 mm Hg at 20
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 74 .6 .
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 .1 .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) ; an d
Janitorial cleaning, including graffiti removal (Rule
74 .6 .C .l .c )
9 . 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 shall perform solvent cleaning unless one o f
Page 7
03/22/200 0
HDMSPOO131650
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
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 th e
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 .
10 . 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 .
11 . 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 .
12 . 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 50, Opacity, and APCD Rule 51, Nuisance .
13 . In order to comply with APCD Rule 50, Opacity, the permittee shall
control fugitive emissions from the soil handling operations as
necessary in order to prevent visible emissions from exceeding 20%
opacity for more than 3 minutes in any one hour .
14 . 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 .
Page 8
03/22/200 0
HDMSPOO131651
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
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 and
amount of methanol fuel used , emission factor , and the
emissions based on actual engine testing operations . The date,
time , location , number of fuel ( denatured ethanol and methanol)
blowdowns , amount of fuel ( denatured ethanol and methanol) used
for blowdowns , emission factor, and the emissions based on
actual fuel ( denatured ethanol and methanol ) 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- 650 ; the amount of gaseous hydrogen received from
other sources , including the facilities pipeline system, and
destroyed by the flares ; and, an estimate of liquid hydrogen
remaining in Tank Nos . V-122 and V-650 .
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 .
Hyperflow 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 .
Hydrogen Flaring Operations :
The permittee shall maintain records of liquid hydrogen (used
in structural strength testing of Delta IV Fuel Tanks)
combusted in the two flares .
The records shall be compiled
into monthly reports, and shall be summed for the previous
twelve ( 12) months .
Page 9
03/22/200 0
H DMS POO131652
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
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
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 74 .13
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 :
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 Rul e
74 .6 definition .
Soil Screening :
The permittee shall maintain monthly records of the volume, in
cubic yards, of soil handled .
Within 10 days after receipt of this permit, the permittee may petition
Page
10
03/22/200 0
H DMS POO131653
VCAPCD Permit To Operate Number 00232
Issued To Santa Susana Field Laboratory
Valid October 1, 1999 to September 30, 200 0
the Hearing Board to review any new or modified condition
( Rule 22) .
This permit , or a copy, shall be posted reasonably close to the subject
equipment and shall be accessible to inspection personnel ( Rule 19) .
This permit is not transferable from one location to another unless the
equipment is specifically listed as being portable (Rule 20) .
This Permit to Operate shall not be construed to allow any emission unit
to operate in violation of any state or federal emission standard or any
rule of the District .
For :
Karl E . Krause , Manager Richard H . Baldwin
Engineering Section Air Pollution Control Office r
Page
11
03 / 22/200 0
H DMS POO131654