Federal Operating Permit Article 1

This permit is based upon the requirements of Titl e V of the Federal Clean Air Act and Chapter 80, Article 1 of the Commonwealth of Virginia Regul ations for the Control and Abatement of Air Pollution. Until such time as this permit is reopen ed and revised, modified, revoked, terminated or expires, the permittee is authorized to operate in accordance with the terms and conditions contained herein. This permit is issued under the aut hority of Title 10.1, Chapter 13, §10.1-1322 of the Air Pollution Control Law of Virginia. This permit is i ssued consistent with the Administrative Process Act, and 9 VAC 5-80-50 through 9 VAC 5-80-300 of the State Air Po llution Control Board Regulations for the Control and Abatement of Air Pollution of the Commonwealth of Virginia.

Authorization to operate a Stati onary Source of Air Pollution as described in this permit is hereby granted to: Permittee Name: Northrop Grumman Shipbuilding, Inc. Facility Name: Northrop Grumman Shipbuilding, Inc. Facility Location: 4101 Washington Avenue Newport News, Virginia 23607 Registration Number: 60153 Permit Number: TRO-60153

This permit includes the following programs: Federally Enforceable Requirements - Clea n Air Act (Sections I through XIV) State-Only Enforceable Re quirements (Section XV)

June 1, 2009 Effective Date

May 31, 2014 Expiration Date

_________________________________________ Regional Director

June 1, 2009 Signature Date Table of Contents, pages 2-3 Permit Conditions, pages 4-99Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 June 1, 2009 Page 2

Table of Contents

I. FACILITY INFO RMATION .......................................................................................................4

II. EMISSION UNITS ................................................................................................................. .......8

III. FUEL BURNING EQUIPMENT REQUIREMENTS..............................................................25

A. L IMITATIONS

............................................................................................................................... ...............25 B. M ONITORING

............................................................................................................................... ...............29 C. R ECORDKEEPING

............................................................................................................................... .........31 D. T ESTING

............................................................................................................................... ......................33 E. N OTIFICATIONS AND R EPORTING ..............................................................................................................33

IV. FOUNDRY OPERATION REQUIREMENTS.........................................................................35

A. L IMITATIONS

............................................................................................................................... ...............35 B. M ONITORING

............................................................................................................................... ...............37 C. R ECORDKEEPING

............................................................................................................................... .........45 D. T ESTING

............................................................................................................................... ......................46 E. N OTIFICATIONS AND R EPORTING ..............................................................................................................49

V. STEEL PREPARATION AND FABRI CATION REQUIREMENTS....................................50

A. L IMITATIONS

............................................................................................................................... ...............50 B. M ONITORING

............................................................................................................................... ...............51 C. R ECORDKEEPING

............................................................................................................................... .........51 D. T ESTING

............................................................................................................................... ......................52

VI. SECONDARY LEAD PROCESSI NG REQUIREMENTS......................................................52

A. L IMITATIONS

............................................................................................................................... ...............52 B. M ONITORING

............................................................................................................................... ...............53 C. R ECORDKEEPING

............................................................................................................................... .........54 D. T ESTING

............................................................................................................................... ......................54

VII. WOODWORKING.................................................................................................................... ..55

A. L IMITATIONS

............................................................................................................................... ...............55 B. M ONITORING

............................................................................................................................... ...............56 C. R ECORDKEEPING

............................................................................................................................... .........56 D. T ESTING

............................................................................................................................... ......................56

VIII. ELECTROPLATING OPERATIONS.......................................................................................57

A. L IMITATIONS

............................................................................................................................... ...............57 B. M ONITORING

............................................................................................................................... ...............58 C. R ECORDKEEPING

............................................................................................................................... .........59 D. T ESTING

............................................................................................................................... ......................59 E. R EPORTING

............................................................................................................................... .................60

IX. PAINTING OPERATIONS ........................................................................................................61

A. L IMITATIONS

............................................................................................................................... ...............61 B. M ONITORING AND R ECORDKEEPING .........................................................................................................65 C. T ESTING

............................................................................................................................... ......................68 D. R EPORTING

............................................................................................................................... .................68Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 June 1, 2009 Page 3 X. SPECIALTY SHOPS REQUIREMENTS.................................................................................69

A. L IMITATIONS

............................................................................................................................... ...............69 B. M ONITORING

............................................................................................................................... ...............71 C. R ECORDKEEPING

............................................................................................................................... .........71 D. T ESTING

............................................................................................................................... ......................72

XI. MISCELLANEOUS ACTIVITIES ............................................................................................72

A. L IMITATIONS

............................................................................................................................... ...............72 B. M ONITORING

............................................................................................................................... ...............74 C. R ECORDKEEPING

............................................................................................................................... .........76 D. T ESTING

............................................................................................................................... ......................76

XII. INSIGNIFICANT EMISSION UNITS ......................................................................................77

XIII. PERMIT SHIELD & INAPPLICABLE REQUIREMENTS ..................................................87

XIV. GENERAL CONDITIONS .........................................................................................................88

A. F EDERAL E NFORCEABILITY .......................................................................................................................88 B. P ERMIT E XPIRATION

............................................................................................................................... ...88 C. R ECORDKEEPING AND R EPORTING ............................................................................................................89 D. A NNUAL C OMPLIANCE C ERTIFICATION .....................................................................................................90 E. P ERMIT D EVIATION R EPORTING ................................................................................................................90 F. F AILURE /M ALFUNCTION R EPORTING ........................................................................................................91 G. S EVERABILITY

............................................................................................................................... ............92 H. D UTY TO C OMPLY

............................................................................................................................... .......92 I. N EED TO H ALT OR R EDUCE A CTIVITY NOT A D EFENSE ............................................................................93 J. P ERMIT M ODIFICATION .............................................................................................................................93 K. P ROPERTY R IGHTS

............................................................................................................................... ......93 L. D UTY TO S UBMIT I NFORMATION ...............................................................................................................93 M. D UTY TO P AY P ERMIT F EES .......................................................................................................................93 N. F UGITIVE D UST E MISSION S TANDARDS ....................................................................................................94 O. S TARTUP
, S HUTDOWN
, AND M ALFUNCTION .............................................................................................94 P. A LTERNATIVE O PERATING S CENARIOS .....................................................................................................94 Q. I NSPECTION AND E NTRY R EQUIREMENTS .................................................................................................95 R. R EOPENING F OR C AUSE .............................................................................................................................95 S. P ERMIT A VAILABILITY ..............................................................................................................................9 5 T. T RANSFER OF P ERMITS ..............................................................................................................................9 6 U. M ALFUNCTION AS AN A FFIRMATIVE D EFENSE .........................................................................................96 V. P ERMIT R EVOCATION OR T ERMINATION FOR C AUSE ................................................................................97 W. D UTY TO S UPPLEMENT OR C ORRECT A PPLICATION ..................................................................................97 X. S TRATOSPHERIC O ZONE P ROTECTION .......................................................................................................97 Y. A SBESTOS R EQUIREMENTS ........................................................................................................................98 Z. A CCIDENTAL R ELEASE P REVENTION .........................................................................................................98 AA. C HANGES TO P ERMITS FOR E MISSIONS T RADING ......................................................................................98 BB. E MISSIONS T RADING

............................................................................................................................... ...98

XV. STATE-ONLY ENFORCEABLE REQUIREMENTS.............................................................99Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 4



### I. Facility Information

Permittee Northrop Grumman Shipbuilding, Inc. (NGSB, fo rmerly Newport News Shipbuilding and Dry Dock Company), a subsidiary of Northrop Grumman Corporation 4101 Washington Avenue Newport News, Virginia 23607

Facility Northrop Grumman Shipbuilding, Inc. 4101 Washington Avenue Newport News, Virginia 23607

Responsible Official James. R. Thornton Director, Environmental, H ealth and Safety (757) 380-4651

Contact Person William M. Cash-Robertson Senior Environmental Engineer (757) 534-4068

County-Plant Identification Number: 51-700-00013

Facility Description: NAICS 336611

Northrop Grumman Shipbuilding, Inc. (NGSB) is a subsidiary of Northrop Grumman Corporation. NGSB owns and operates a major ship construction and overhaul facility in Newport News, Virginia. The facility is classi fied as a major source for criteria and hazardous air pollutant emissions from its various operations. It is ther efore subject to Title V operating permit requirements. Products manufactured include U.S. Navy contracted aircraft carriers and submarines, as well as ships for commercial appli cations such as oil tank ers and service ships. Services performed at the facility include all activities related to the repair, overhaul, and conversion of ships. The facility can be divide d up into several operational segments as follows: Fuel Burning Equipment - NGSB operates several boilers and other pieces of combustion equipment on site. The main steam plant consists of three boilers fired with No. 6 fuel oil and/or recovered oil, each rated at 135 MMBTU/hour. The facility also has two barge-mounted boilers each rated at 213.26 MMBTU/hour firing No. 6 fuel oi l. For a new contract with the Navy, the facility applied for a minor New Source Review permit for two temporary boilers rated at 245.3 MMBTU/hour each, firing 0.05% sulfur distillate oil. The permit was issued on April 24, 2006, and amended on June 4, 2007. There are ovens /furnaces larger than 10 MMBTU/hr firing propane or No. 2 fuel oil that belong to the Steel Preparation and Fa brication Operation, theNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 5 Foundry Operation, and Miscellaneous Activitie s, however, they are addressed under Fuel Burning Equipment. The facility also uses a nu mber of diesel-fired internal combustion engines for emergency generators or air compressors ranging in size from around 1,500 hp to less than 100 hp. Depending on the size and usage, some qua lify as insignificant ac tivities; otherwise, they are also included in Fuel Burning Equipment section.

Foundry Operations - Alloy steels, copper-nickel, aluminum , brass, and other non-ferrous alloys can be produced at the facil ity foundries for a full range of castings necessary for the construction/repair of ships. Foundry operati ons generally include th e following processes: melting, casting, finishing, and sand handling. All oying agents and fluxing materials are added to the furnaces as needed for a given casting type . The molten metal is poured into sand molds, allowed to cool, and the casti ngs are separated from the mold s at shakeout. The sand is recovered while the castings move to the fini shing area. Finishing involves removal of extraneous metal by burning-off, blasting, and gri nding. The facility also has a pattern shop to develop and refine the large and complex patter ns for such castings as struts, rudders, stern frames, valves, compressor castings, pipes, etc. The sand handling system includes unloading of sand into storage silos, mixing of sand with re sin, transferring the sand to machines for the production of molds or cores, and collecting the return sand from the shakeout area. Sand molds provide the exterior shape of the casting. Cores are used for specifi c internal voids (for example, recessed curves and hollow areas). The foundry us es three electric arc furnaces (EAFs) and one argon/oxygen-degassing furnace (AOD). The EAFs are subject to the Iron and Steel Foundries MACT (40 CFR 63 Subpart EEEEE). A new particul ate emissions control system with a high efficiency cartridge particulate removal system was installed in 2007 to comply with the MACT. The AOD was permitted on 2/24/1978. It is in the sa me building as the EAFs, not subject to the MACT but subject to Compliance Assurance Mo nitoring (CAM). The New Sand Operation and the Sand Reclaim Operation are also subject to CAM. The small brass foundry uses Electric Induction Furnaces for metal melting.

Steel Preparation and Fabrication Operations - Blasting and coating of steel units are conducted in a blast and coat facility that has compute r-controlled temperature and humidity to prevent "flash rust" corrosion on freshl y blasted surfaces. The steel units being blasted and coated include plates, I-beams, and other "shapes". After shot blasting the modules, the on-site rail lines carry plates to the fabrication and/or production facilities. Emi ssions are primarily particulate matter and are exhausted to baghouses. In the steel fabrication facility, steel plates of varying thickness and sizes are rolled and shaped. Operations include flame cutting, grinding/sh earing, cold and hot forming, planing/milling, punching/drilling, and sawing. The steel production f acility is an eleven acre complex for the fabrication of structural st eel, ranging from small components to complex 300-ton ship subassemblies. Operations incl ude plate preparation, flame plan ers, automated panel line, web lines, numerically controlled burn ing machines, flat and curved block shops, and machinery for assembly of circular hull plates. Plate prepar ation includes some shot blasting and heating to prepare the surface for the next st ep in the process, painting.

Secondary Lead Processing - This facility makes lead shielding plates for reactor spaces and personal protection. For this process, only pure lead ingots are utilize d. The process involvesNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 6 the preheating of the ingots prior to melting in furnaces. The metal is then contoured at hot benches and finished using radiant heaters. As permitted on 12/16/1981, there are two main process lines contained within the building (No. 4582) and a lead school for training. The facility uses propane for pro cess heating. Particulate and l ead emissions are controlled by baghouses.

Woodworking Operations - Woodworking operations associat ed with the facility's primary function, shipbuilding, generally occur at two loca tions. Building No. 3 primarily makes pallets, boxes, and shoring timbers. Equipment used incl udes molders, surfacers, saws, planers, lathes, boring machines and drills, shapers, and joiners in various sizes. The model shop is a smaller facility (2,400 square feet) used for fabrication of ships from w ood, plastic, or Plexiglas. Fullscale models of these materials are used as trai ning aids, for demonstrati ons, or for verification of design. Wood is also used to make some mo ld patterns on the second floor of Building 501 and produce pallets and shipping co ntainers at Building 513. Partic ulate emissions are controlled by cyclones.

Electroplating - The electroplating plant performs chro me, silver, zinc, cadmium, lead, copper, and nickel plating, chemical cleaning, pickling, stripping, buffing, and polishing. Chemical cleaning, pickling, stripping, buffing, and polishing are part of the cleaning and preparation of a substrate such as metal for electroplating. Electroplating provides improved corrosion resistance, appearance, frictional characteristi cs, wear resistance and hardness, and specific electrical properties for ship hard ware and parts. The facility is subject to the MACT of 40 CFR 63 Subpart N- National Emission St andards for Chromium Emissions from Hard and Decorative Chromium Electroplating a nd Chromium Anodizing Tanks.

Painting/Coating Operations – The facility is subject to the MACT of 40 CFR 63 Subpart IINational Emission Standards for Shipbuilding and Ship Repair (Surface Coating). Painting/coating operations associated with the fa cility's primary function, shipbuilding, occur at various locations throughout the f acility. Paint booths are locate d in the fabrication areas and numerous shops (e.g., machine, electric, and hull outfitting). Outside pa inting occurs in areas such as dry docks, assembly platens, Quonset hu ts, in the open, under extemporaneous or semiportable cover, inside, and outside of buildi ngs. Brush, roller, spra y, and touch-up painting applications for vessel or non-vessel related items also occur in many opera tional areas. Paints are generally purchased in small containers (1 to 5 gallons) and then mi xed (thinned, if needed) in 5 to 10-gallon paint pots. Th ese pots feed spray gun applicators. In Buildings 274, 275, and 1746, pressurized totes ranging in capacity from 200 to 400 gallons are used. These units are closed-loop to minimize emissions. Unit cleani ng is also done in the closed-loop mode. Thinners are purchased in 55-gallon containers. By utilizing relatively small containers rather than large storage tanks, the f acility can more effectively m eet customer requirements and control quantities of potentially VOC and HAP-containing materials at the facility. The facility was permitted on 2/12/86 for a paint spray room w ith water wash curtains, associated with the aluminum flame spray facility. The facility al so houses a powder coating operation in Buildings 205 which was initially permitted on 7/10/2000; the permit was then amended on 2/14/2001.Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 7 Specialty Shops - Machine shops are located at various lo cations at the facil ity. Work at the various machine shops involves metal cleaning, machining, and fabrication of large plates, smaller parts, pipe cutting, and si milar activities. Several buildi ngs house very large lathes and milling equipment for turning large me tal plates and other large parts. Piping is fabricated and assembled at the pipe fa brication facility. Equi pment includes horizontal boring mills, standard and radial drill presses, la thes, automatic welding machines, standard pipe bending machines, a variable radius pipe roller-bender, pipe thread ers, etc. Metal machining and surface preparation are also performed at the pipe fabrication facility. Electrical shops are locat ed at several locations at the f acility, manufacturing, maintaining, testing and repairing electri cal equipment of all sizes. While the above operations handle metal parts, plastic components are processed by the melamine operations. Particulate emissions are exhaus ted to cyclones or baghouses. There are also facility-wide parts washer operati ons that use cleaning solv ents that have been determined not subject to 40 CFR Part 63 S ubpart T - National Emissions Standards for Halogenated Solvent Cleaning.

Miscellaneous Activities - Other miscellaneous activities at the source include facility-wide abrasive blasting, grit off-loading, grinding, cutting, welding/brazing, gluing, solvent usage, wastewater treatment, asbestos handling, shipboard foam inst allation applications, vessel cleaning, radionuclides, genera l plant activities (welding, sa ndblasting, general carpentry, cleaning, vehicle maintenance, offset printi ng, blueprinting, copying, a nd firefighting), two gasoline service stations, and research and deve lopment activities. Facility-wide abrasive blasting, grit off-loading, and welding/brazi ng listed under FAC-BLAST, FAC-GRIT, and FACWELD, respectively, include only those activities that have to be done outside without controls. Note that the arc gouger operation (NSR permit da ted 9/02/94) and the blasting units (205-B1 and 205-B2) for the powder coating operation (NSR permit dated 2/14/01) are addressed in this section in accordance with the permit application.

Facility also has remediation activities which are regulated by the RCRA program. Predicted VOC and HAP emissions from the Vapor Extraction System have been determined to be exempt from minor NSR permitting as well as qualify for the exemption from MACT Subpart GGGGG except for the recordkeeping requirements in 40 CFR 63.7881(c) (2) (See VA DEQ letter dated November 28, 2007).

Storage Tanks - Storage tanks ranging in size fr om <1,000 gallons up to 500,000 gallons are located at the facility. Most tanks are used fo r storage of petroleum related materials including No. 6 fuel oil, diesel oil, wast e oil, and oily wastewater. Some process related storage tanks are pressurized, e.g., varnish tanks. Totes (200 to 40 0 gallons), 55-gallon drums, and pots (5 to 10 gallons) are used for painting activ ities. Underground storage tanks serving the gasoline service stations include one 10,000-gallon tank and two 6,000-gallon tanks. NGSB utilizes propane for heaters, dryers, and ovens. Three 30,000-ga llon storage tanks and one 70,000-gallon tank are used to supply these units. Natural gas is also used in some areas of the yard and is supplied by outside commercial suppliers thr ough trunk lines. All the tanks are not subject to NSPS Subpart Kb or 9 VAC 5-40-3410 (Rule 4-25), and they qualify as insignificant activities.Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 8II.Emission UnitsEquipment to be operated consists of:Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDateFuel Burning Equipment/ Steam BoilersFTSF-E1FTSF-S1No. 6 fuel oil-firedbarge- mounted boiler,CombustionEngineering ModelV2M-8, pre-1983213.26MMBTU/hr_ _ _ 1/13/85 NSR permitFTSF-E2 FTSF-S2No. 6 fuel oil-firedbarge- mounted boiler,CombustionEngineering ModelV2M-8, pre-1983213.26MMBTU/hr_ _ _ 1/13/85 NSR permit78-E1 78-S1No. 6 fuel oil orrecovered oil-firedboiler, B&W IntegralFurnace, 1948135 MMBTU/hr _ _ _ 1/13/85 NSR permit78-E2 78-S1No. 6 fuel oil orrecovered oil-firedboiler, B&W IntegralFurnace, 1948135 MMBTU/hr _ _ _ 1/13/85 NSR permit78-E3 78-S1No. 6 fuel oil orrecovered oil-firedboiler, B&W IntegralFurnace, 1948135 MMBTU/hr _ _ _ 1/13/85 NSR permitNorthrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 9Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDateTS-E1 TS-S1No. 2 fuel oil,manufactured 1994245.3MMBTU/hrLow NOx Burner _ NOx 6/04/07 NSR permitTS-E2 TS-S2No. 2 fuel oil,manufactured 1997245.3MMBTU/hrLow NOx Burner _ NOx 6/04/07 NSR permitFuel Burning Equipment/ Steel Preparation and Fabrication276-E1 276-S1Propane-fired oven,construction dateunknown15.3 MMBTU/hr _ _ _ _276-E2 276-S2Propane-fired RayCampbell Furnace,construction dateunknown15.4 MMBTU/hr _ _ _ _Fuel Burning Equipment/ Foundry550-E8 550-S8Propane-fired heattreating furnace # 578415.3 MMBTU/hr _ _ _ _550-E9 550-S9Propane-fired heattreating furnace # 530227 MMBTU/hr _ _ _ _550-E13 550-S13Propane-fired heattreating furnace #5753112 MMBTU/hr _ _ _ _Fuel Burning Equipment/ Miscellaneous Activities1278-E1 1278-S1Annealing oven-Northside, #2 oil20.79MMBTU/hr_ _ _ _36-38152 _Generator, stationary,Nancy Lee, diesel672 HP _ _ _ _76-4179 _ Generator B905, diesel 672 HP _ _ _ _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 10Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate1-35058 _Generator, portable,diesel740 HP _ _ _ _2-35060 _Generator, portable,diesel740 HP _ _ _ _60-40340 _Generator, portabletransfer car, diesel740 HP _ _ _ _23 - 91090 _Generator, stationaryDD12 B1753, diesel759 HP _ _ _ _11 - 41703 _Generator, MOS BoilerOperations, diesel980 HP _ _ _ _17 - 35738 _Generator, portable,diesel980 HP _ _ _ _21 - 71128 _Generator, stationaryPL 13 SGCC, diesel1620 HP _ _ _ _34 - 36859 _Generator, stationaryB4636, diesel1479 HP _ _ _ _58 - 39934 _Generator, stationaryFDD port, diesel1479 HP _ _ _ _59 - 40005 _Generator, stationaryFDD STBD, diesel1479 HP _ _ _ _42030, 42031,42032, 42033,42302, 42303,42304, 42305,42306, 42307,42308_Eleven (11) Sullair1300, Caterpillar dieselengine / model 3406,diesel480 HP each_ _ _ _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 11Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDateFoundry Operations550-E1Argon/OxygenDegassing Furnace,Whiting Corporation25 ton/hr2/24/78 NSR(CAM applicable)550-E2 Electric Arc Furnace A 3 ton/hr550-E3 Electric Arc Furnace B 3 ton/hr550-E4 Electric Arc Furnace C 3 ton/hr550-E12550-S1Riser Burn Booth, handtorches0.068 ton/hrCartridge Filtersystem, DonaldsonTorit- Downflo Oval4-128, 99.9% designcontrol efficiency550-C1a PM_550-EF1 _Charging/TappingOperations12.5 ton/hr_ _ _ _550-EF2 _Pouring casting/Castingcooling Operation25 ton/hr_ _ _ _550-EF5 _ Shakeout Operations NA_ _ _ _550-E10 _ Abrasive Saw, #5453 0.02 tons/hrDust collector ventinginside the building_ PM _550-E20 550-S20Steel Shot AbrasiveBlasting, #56106 tons/hrBaghouse, 95%design controlefficiency550-C20 PM _550-E21 550-S21Sawing operation,#56160.01 tons/hrCyclone, 70% designcontrol efficiency550-C21 PM _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 12Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate555-E11Sand ReclaimOperations, hopper12.5 tons/hr555-EF3555-S11Riser Burn Area,#34561, hand torches0.068 ton/hrBaghouse, StandardHavens Alpha MarkIII, size 24 SH,#34561, 95% designcontrol efficiency555-C11 PM_(CAM applicable to555-E11)555-E1 555-S1New Sand Operations,#40645, hopper100 tons/hrCartridge filters,Torit 2DF12Downflow, #40645,99% design controlefficiency555-C1 PM_(CAM applicable)528-EF1 _ Abrasive Blasting 50 lbs/hr_ _ _ _528-EF2_Riser Burn Area NA_ _ _ _556-EF1_Electric InductionFurnaces (4 each)0.5 to 4 tons_ _ _ _556-EF2_Gas Furnace 90 Lbs_ _ _ _556-EF3_Pouring casting/Castingcooling Operation4 ton/hr_ _ _ _Steel Preparation and Fabrication Operations1746-E1 1476-S1Abrasive Blasting- SteelShots, PangbornRotoblast2.5 tons/hrPangborn DustCollector, 95% designcontrol efficiency1746-C1 PM _274-E1 274-S1 Abrasive Shot Blasting 2.5 tons/hrWheelabrator #19,Model 126D, 95%design controlefficiency274-C1 PM _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 13Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate275-E5 275-S5 Abrasive Shot Blasting 2.5 tons/hrPangborn C70, TypeCM, 95% designcontrol efficiency275-C5 PM _276-E3 276-S3Wire Brush PaintRemoval_Torit dust collector,Downflow DFT4-16cartridge filter, 99%design controlefficiency276-C3 PM _276-E3PCBuildingventsPlasma Cutting _ _ _ _ _288-E1 288-S1Abrasive Blasting- Steelshots2.5 tons/hrRF Cox Associatesbaghouse, 95% designcontrol efficiency288-C1 PM _288-E2288-S2Abrasive Blasting- Steelshots2.5 tons/hrRF Cox Associatesbaghouse, 95% designcontrol efficiency288-C2 PM _288-E3288-S3Abrasive Blasting- Steelshots2.5 tons/hrRF Cox Associatesbaghouse, 95% designcontrol efficiency288-C3 PM _288-E4288-S4Abrasive Blasting- Steelshots2.5 tons/hrRF Cox Associatesbaghouse, 95% designcontrol efficiency288-C4 PM _Secondary Lead Processing4582-E1 throughE64582-S1Lead Contouring HotBenches4.7 tons/hrcombinedBaghouse, StandardHavens Alpha MarkIII 18, 99.0% designcontrol efficiency4582-C1 PM 12/16/81 NSR permitNorthrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 14Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate4582-E12 4582-S2Lead Casting Furnacesand Conveyor System4.7 tons/hrBaghouse, StandardHavens Alpha MarkIII 18, 99.0% designcontrol efficiency4582-C2 P M 12/16/81 NSR permitLS-E1 4582-S3Lead School (fortraining) with 3 workstations0.05 tons/hrBaghouse, StandardHavens Alpha MarkIII 18, 99.0% designcontrol efficiency4582-C3 PM 12/16/81 NSR permitWood Working3-E1 3-S1 Cutting/Planer/Re-saw _Cyclone, 90.0%design controlefficiency3-C1 PM _501-E2 501-S2Foundry Pattern Shop -wood cutting machines_Cyclone, 90.0%design controlefficiency501-C2 PM _513-E1 513-S1 Warehouse No. 6 Saws _Cyclone, 90.0%design controlefficiency513-C1 PM _ElectroplatingPLATE-E1Chromiumelectroplating tank #63,Plateg Corp., POP68919-R129 ft3/hourPLATE-E2Chromiumelectroplating tank #49,Plateg Corp., POP68919-R32 ft3/hourPLATE-E34620-S1Chromiumelectroplating tank #59,Plateg Corp., POP68919-R129 ft3/hourZenon packed towerscrubber, 98.0%design controlefficiency4620-C1 PM _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 15Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDatePainting OperationsPainting Operations/Group P-X33232-E1 throughE6232-S1through S6Consolidated PaintFacility, 2 banks of 3paint booths each (6total)_BinksDynaprecipitator,water wash curtain,98% design controlefficiency232-C1 throughC6PM-10 _4681-E2 4681-S2Metal Finishing Bldg,paint booth (Znphosphate coating line),automated_GreenlineCorporation, waterwash curtain, 98%design controlefficiency4681-C2 PM-10 _4681-E3 4681-S3Metal Finishing Bldg,paint booth, manual_GreenlineCorporation, waterwash curtain, 98%design controlefficiency4681-C3 PM-10 _4701-E10 4701-S10Aluminum Wire FlameSpray booth, manual_Global FinishingSolutions water washcurtains, 98% designcontrol efficiency4701-C10 PM-10 2/12/86 NSR permit4701-E11 4701-S11Aluminum Wire FlameSpray booth, manual_Global FinishingSolutions water washcurtains, 98% designcontrol efficiency4701-C11 PM-10 2/12/86 NSR permit4701-E12 4701-S12Flame Spray Facilitypaint booth, north unit,manual_Global FinishingSolutions water washcurtains, 98% designcontrol efficiency4701-C12 PM-10 2/12/86 NSR permitNorthrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 16Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate4701-E13 4701-S13Flame Spray Facilitypaint booth, south unit,manual_Global FinishingSolutions water washcurtains, 98% designcontrol efficiencyefficiency4701-C13 PM-10 2/12/86 NSR permit4702-E1 4702-S1Paint Spray Bldg,antenna paint booth_Filter (paper), JBIAutomatic SprayBooth, 90% designcontrol efficiency4702-C1 PM-10 _4730-NP 4730-NPFEGrit Blast & PaintFacility, North PaintRoom_Filter (paper), 90%design controlefficiency4730-NPC PM-10 _4730-SP 4730-SPFEGrit Blast & PaintFacility, South PaintRoom_Filter (paper), 90%design controlefficiency4730-SPC PM-10 _Painting Operations/P-SHIPSPRAYP-SHIPSPRAY _Outside Vessel Painting-manual spray painting_ _ _ _ _Painting Operations/P-SHIPBRUSHP-SHIPBRUSH _General facility-widemarine coatingoperations, brush, roller,and touch-up applicationon vessels and vesselparts- manual brushpainting_ _ _ _ _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 17Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDatePainting Operations/Powder Coating Operation205-C1a205-C1b205-C1c205-C1aS205-C1bS205-C1cSParts Washer withthree burners,natural gas-fired,Eclipse ImersojetIJ6One burner ratedat 2.0MMBTU/hr andtwo burners ratedat 1.3MMBTU/hr each_ _ _ 2/14/01 NSR Permit205-C2 205-C2SPreheat oven,natural gas-fired,Eclipse AH520Burner andevaporator ratedat 5.5MMBTU/hr_ _ _ 2/14/01 NSR Permit205-C3 205-C3SCure oven, , naturalgas-fired, EclipseAH520Burner andevaporator ratedat 5.5MMBTU/hr_ _ _ 2/14/01 NSR Permit206-C1 206-C1SHeat cleaning oven,propane-fired,Steelman Model4.56.54 BA-C0.6 MMBTU/hrDirect FlameAfterburner, 99.0%design controlefficiency206-C1C VOC 2/14/01 NSR Permit205-PDR _Nordson PowderBooth, powdercoating booth2,160 lbs/hour _ _ _ 2/14/01 NSR permitPainting Operations/Group P-X15274-E13 274-S13Plate Preparation &Inspection, paintbooth_Dry filter (paper),90% design controlefficiency274-C13 PM-10 _275-E4 and 275-E6275-S4 and 275-S6, resp.Shape Preparation,paint booths (two)_Dry filter (paper),90% design controlefficiency275-C4 and 275-C6, resp.PM-10 _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 18Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate1746-E4 1746-S4Plate Preparation &Inspection, paintbooth_Filter (paper), ESABHEBE, 90% designcontrol efficiency1746-C4 PM-10 _60-E5 _ Engraving _ _ _ _ _Painting Operations/Group P-FACP-FAC _General facilitywide non-vesselbrush, roller, sprayand touch-uppainting operationsmanual brush andspray painting_ _ _ _ _103-E2 103-S2Maintenance Shop,paint booth_Filter (paper), 90%design controlefficiency103-C2 PM-10 _Specialty Shops64-E1 64-S1Electrical Shop drillpress/sander (notused for wood)_Baghouse, 95%design controlefficiency64-C1 PM _64-E2 64-S2 Electrical Shop saw _Baghouse, 95%design controlefficiency64-C2 PM _64-E9 64-S9 Grinding metal _Cyclone, 90% designcontrol efficiency64-C9 PM _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 19Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate60-E2 60-S2 Grinding operations _Cartridge filtersDonaldson ToritDownflow DFO3-12,99% design controlefficiency60-C2 PM _114-E1 114-S1 Saw metals _Cartridge filtersDonaldson ToritDownflow 2DF8,#40859, 99% designcontrol efficiency114-C1 PM _4896-E1 4896-S1MelamineOperations (2Milling Machines,Band Saw, andLathe)_Dust collector,Donaldson ToritModel 90-219-5, 99%control efficiency4896-C1 PM _64-E3 64-S3Bayco burn-outoven, Model BB288, using propane,19791 MMBTU/hrAfterburner, 1MMBTU/hr64-C3 PM 10/18/1979 NSR PermitFAC-PW Building ventsFacility-wide parts-washer operations__ _ _ _Miscellaneous ActivitiesFAC-BLST _External abrasiveblasting - facilitywide_____FAC-GRIT _Utility grit off-loading_____Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 20Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate50-E1 50-S1Wheelabrator#11980 Table BlastUnit -Abrasiveblasting/steel shots2.5 tons/hrCartridge filters, ToritUltraweb DownflowII DFT3-12, 99%design controlefficiency50-C1 PM _17-E20 _Abrasive blastingglove box/sand andglass, Vacublast 93-2788___ _ _4730-NR(NorthsideReclaim)_Torit UltrawebCartridge Dustcollector, 99.0%design controlefficiency4730-NRC PM _4730-NB4730-NLE(Northside LocalExhaust)Abrasiveblasting/steel shot -North Blast Room_Torit UltrawebCartridge Dustcollector, 99.0%design controlefficiency4730-NLC PM _4730-SR(SouthsideReclaim)_Torit UltrawebCartridge Dustcollector, 99.0%design control4730-SRC PM _4730-SB4730-SLE(Southside LocalExhaust)Abrasiveblasting/steel shot -South Blast Room_Torit UltrawebCartridge Dustcollector, 99.0%design controlefficiency4730-SLC PM _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 21Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate201-E1 201-S1Abrasiveblasting/steel shot(10/1970),Wheelabrator #76142.5 tons/hrCartridge filters ToritUltraWeb DownflowDFO3-12, 99%design controlefficiency201-C1 PM _Port-E1 Port-S1Abrasiveblasting/steel shot_Baghouse, StandardHavens 12SH AlphaMark III, 95.0%design controlefficiencyPort-C1 PM _Port-E2 throughPort E-3Port-S2 throughPort-S3Abrasiveblasting/utility grit_Baghouse, TorritModel MTD-48-LD,95.0% design controlefficiencyPort-C2 throughPort-C3PM _Port-E4 throughPort E-24Port-S4 throughPort-S24Abrasiveblasting/utility grit_Baghouses (21 units),Vaculblast Co. ModelD6 or D6S-8W,95.0% design controlefficiency, eachPort-C4 throughPort-C24PM _Port-E25 Port-S25Abrasiveblasting/utility grit_Baghouse,MISCO/IPECcustom-made unit,95.0% design controlefficiencyPort-C25 PM _Port-E26 throughPort-E31Port-S26 throughPort-S31Abrasiveblasting/utility grit_Baghouses (6 units),MISCO/IPECcustom-made units,95.0% design controlefficiency, eachPort-C26 throughPort-C31PM _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 22Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate4701-E1 4701-S1Abrasiveblasting/steel grit,garnet, aluminumoxide384 lbs/hrBaghouse,MISCO/IPECcustom-made units,95 % design controlefficiency4701-C1 PM _1768-E1 1768-S1Grinding/cutting/welding - WeldingSchool_Cyclone, Torit,90 % design controlefficiency1768-C1 PM _FAC-WELD _Welding- facility-wide___ _ _250-E1 250-S1Welding/leadcaulking operations_Fabric filter, PortableHawley TRAV-L ventfabric filter withHEPA filter dustcollector, 95 % designcontrol efficiency250-C1 PM _263-E1 263-S1 Welding operations _Fabric filter, PortableHawley TRAV-L ventfabric filter withHEPA filter dustcollector, 95.0%design controlefficiency263-C1 PM _4677-E1 4677-S1 Welding operations _Baghouse, 95.0%design controlefficiency4677-C1 PM _250-E2 250-S2Arc gougeroperations_Fabric filter, PortableHawley TRAV-L ventfabric filter withHEPA filter dustcollector, 95.0%design controlefficiency250-C2 PM 9/02/94 NSR permitNorthrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 23Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDateFAC-GLUE _Gluing operations-facility-wide___ _ _ALC-E1 _Abrasive blastingusing ALC portableblasting machine,Model F-600R,2006800 lbs/hr__ _ _501-E5 501-S5 Asbestos cutting NALow efficiencycyclone501-C5 PM _75-E5 75-S5Asbestos & nonasbestos cutting ofgasketsNADust Collector workbench, Torit ModelDD or Model 130,design controlefficiency unknown75-C5 PM _74-E1 74-S1 Polyethylene cutting NABaghouse, 95.0%design controlefficiency74-C1 PM _FAC-SOLV _Solvent/thinnerusage- facility-wide___ _ _175-E1 _Fiberglassoperations_ __ _ _SS-E1 throughSSE2_Service stations -gasoline_ __ _ _5-E2 5-S2Wheelabrator/Tumblast Machine(Blast Unit)-Abrasive Blasting/steel shots2.5 tons/hrBaghouse,WheelabratorDustube Model 112-AC, 95.0% designcontrol efficiency5-C2 PM _Northrop Grumman Shipbuilding, Inc.Permit Number: TRO-60153Effective Date: June 1, 2009Page 24Emission UnitIDStack IDEmission UnitDescriptionSize/RatedCapacity*Pollution ControlDevice (PCD)DescriptionPCD IDPollutantControlledApplicable PermitDate205-B1 205-S1Powder coating steelshot blast unit_Baghouse,Wheelabrator USF44, design controlefficiency 95%205-BC1 PM 2/14/01 NSR205-B2 205-S2Powder coating steelshot blast unit_Baghouse, PangbornModel 25-5-8, TypeHP-1, design controlefficiency 95%205-BC2 PM 2/14/01 NSRSite RemediationActivities- - --- - -*The Size/Rated capacity is provided here for informational purposes only, and is not an applicable requirement.Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 25



### III. Fuel Burning Equipment Requirements

A. Limitations

Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

FTSF-E1, FTSF-E2, 78-E1, 78-

E2, and 78-E3 Barge-mounted boilers, and steam plant boilers SO 2 2.23 lbs/MMBTU and 2.1% sulfur fuel oil Specific Conditions 5 and 7, 1/30/85 NSR permit

FTSF-E1, FTSF-E2, 78-E1, 78-

E2, and 78-E3 Barge-mounted boilers, and steam plant boilers PM PM emissions shall not exceed E lbs/MMBTU as calculated by the equation E=1.0906H -0.2594 , where H is the total capacity in

MMBTU/hour 9 VAC 5-40-900

78-E1, 78-E2, and

78-E3 Steam plant boilers Opacity Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-940B

276-E1, 276-E2, 550-E8, 550-E9, and 550-

E13 Propane-fired ovens/furnaces PM PM emissions shall not exceed E lbs/MMBTU as calculated by the equation E=1.0906H -0.2594 , where H is the total capacity in

MMBTU/hour 9 VAC 5-40-900

276-E1, 276-E2, 550-E8, 550-E9, and 550-

E13 Propane-fired ovens/furnaces SO 2 SO 2 emissions shall not exceed 2.64 lbs/MMBTU 9 VAC 5-40-930

276-E1, 276-E2, 550-E8, 550-E9, and 550-

E13 Propane-fired ovens/furnaces Opacity Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-940B

1278-E1 No. 2 fuel oil-fired annealing oven PM PM emissions shall not exceed E lbs/MMBTU as calculated by the equation E=1.0906H -0.2594 , where H is the total capacity in

MMBTU/hour 9 VAC 5-40-900Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 26
Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

1278-E1 No. 2 fuel oil-fired annealing oven SO 2 SO 2 emissions shall not exceed 2.64 lbs/MMBTU 9 VAC 5-40-930

1278-E1 No. 2 fuel oil-fired annealing oven Opacity Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-940B

TS-E1 and

TS-E2 Temporary distillate oil-fired boilers Opacity Visible emissions from the boilers shall not exceed 20 percent opacity except during one six-minute period in any

one hour in which visible emissions shall not exceed 27 percent opacity as determined by EPA Method

9 (reference 40 CFR 60, Appendix A). These limits

apply at all times except during periods of startup, shutdown, or malfunction. 9 VAC 5-80-110 and Condition 11 of 6/04/07 NSR permit

36-38152
76-4179
1-35058
2-35060
60-40340
23 - 91090
11 - 41703
17 - 35738
21 - 71128
34 - 36859
58 - 39934
59 - 40005

42030, 42031, 42032, 42033, 42302, 42303, 42304, 42305, 42306, 42307, 42308 Electrical generation and mechanical work diesel engines Opacity Opacity of existing units (pre 1972) is limited to 20% except for one 6-minute period in each hour in which

opacity shall not exceed 60%.

Opacity of new units (post1972) is limited to 20% except for one 6-minute period in each hour in which

opacity shall not exceed 30%. These limits apply at

all times except during periods of startup, shutdown, or malfunction. 9 VAC 5-40-80

9 VAC 5-50-80Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 27 1. Emission Limits - Emissions from each of the fuel burning equipment at the facility shall not exceed the limitations specified in Table III.A. (9 VAC 5-80-110)

2. Fuel Throughput - The two barge-mounted boilers (FTSF-E1 and FTSF-E2) combined shall consume no more than 5 x 10 6 gallons of No. 6 fuel oil per year, calculated monthly as the sum of each consecutive 12-month period. (9 VAC 5-80-110, and Condition 4 of 1/30/85 NSR permit)

3. Fuel Throughput - The two barge-mounted boilers (FTSF-E1 and FTSF-E2) and the three steam plant boilers (78-E1, 78-E2, a nd 78-E3) combined shall consume no more than 14.85 x 10 6 gallons of No. 6 fuel oil and/or recovered oil (combined) per year, calculated monthly as the sum of each consecutive 12-month period. (9 VAC 5-80-110, and Condition 4 of 1/30/85 NSR permit)

4. Fuel- The approved fuel for the barge-mounted boilers FTSF-E1 and FTSF-E2 is No. 6 fuel oil. A change in the fuel ma y require a permit to modify and operate. (9 VAC 5-80-110, and Condition 6 of 1/30/85 NSR permit)

5. Fuel Specifications - The nominal sulfur c ontent of the No. 6 fuel oil to be burned in boilers FTSF-E1, FTSF-E2, 78-E1, 78-E2, and 78-E3 shall not exceed 2.1 percent by weight. The permittee shall maintain records of all No. 6 fuel oil shipments purchased, indicating sulfur c ontent per shipment. These re cords shall be maintained at the facility for inspection by DE Q for the most recent 5-year period. (9 VAC 5-80-110, and Condition 7 of 1/30/85 NSR permit)

6. Emission Controls- Nitrogen oxide (NOx) emissions from the boilers TS-E1 and TSE2 shall be controlled by the use of low NOx technology. (9 VAC 5-80-110, and Condition 3 of 6/04/07 NSR permit)

7. Emission Controls - Sulfur dioxide (SO2) emissions from the boilers TS-E1 and TSE2 shall be controlled by bur ning distillate oil with a maximum sulfur content of 0.05% which more than qualifies as a “very lo w sulfur fuel oil” as defined in 40 CFR 60.41b. (9 VAC 5-80-110, and Condition 4 of 6/04/07 NSR permit)

8. Fuel - The approved fuel for the boilers TS-E1 a nd TS-E2 is distillate oil. A change in the fuels may require a permit to modify and operate. (9 VAC 5-80-110 and Condition 5 of 6/04/07 NSR permit)

9. Fuel Throughput - The two boilers TS-E1 and TS -E2 combined shall consume no more than 3,700,000 gallons of distillate oil per year, calculated monthly as the sum of each consecutive 12-month period. (9 VAC 5-80-110 and Condition 6 of 6/04/07 NSR permit)

10. Fuel Specifications - The distillate oil for boilers TS-E1 and TS-E2 shall meet the specifications below:Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 28

DISTILLATE OIL which meets ASTM D396 sp ecifications for numbers 1 or 2 fuel oil: Maximum sulfur content per shipment: 0.05% As specified in 40 CFR 60.42b(j), the permittee shall demonstrate that the oil meets the definition of “very low sulfur oil” as defined in 40 CFR 60.41b by maintaining fuel certifications as required. (9 VAC 5-80-110 and Condition 7 of 6/04/07 NSR permit)

11. Fuel Certification - The permittee shall obtain a certi fication from the fuel supplier with each shipment of distilla te oil. These certifications meet the requirements of 40 CFR 60.49b(r). Each fuel supplier certif ication shall include the following:

a. The name of the fuel supplier;

b. The date on which the distillate oil was received;

c. The volume of distillate oil delivered in the shipment;

d. A statement that the distillate oil complie s with the American Society for Testing and Materials specifications D396 fo r numbers 1 or 2 fuel oil, and

e. The sulfur content of the distillate oil.

(9 VAC 5-80-110 and Condition 8 of 6/04/07 NSR permit)

12. Operating and Training Procedures - Boiler emissions shall be controlled by proper operation and maintenance of combustion and air pollution control equipment. Boiler operators shall be trained in the proper operation of all such equipment. Training shall consist of a review and familiari zation of the manufacturer’s operating instructions, at minimum. (9 VAC 5-80-110 and Condition 9 of 6/04/07 NSR permit)

13. Emission Limits - Emissions from the operation of the boilers TS-E1 and TS-E2 shall not exceed the limits specified below:

Each Combined

Particulate Matter 3.8 lbs/hour 3.7 tons/year (Filterable) PM-10 1.9 lbs/hour 1.9 tons/year (Filterable) Sulfur Dioxide 13.3 lbs/hour 13.1 tons/year

Nitrogen Oxides 0.20 lbs/MMBTU 39.4 tons/year (as NO 2 ) (30-day rolling average)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 29 Carbon Monoxide 9.4 lbs/hour 9.3 tons/year

Volatile Organic 0.5 lbs/hour 0.5 tons/year Compounds

Lead 0.003 lbs/hour 0.003 tons/year

Except for the lbs/MMBTU NOx limit, these emissions are derived from the estimated overall emission contribution from operating limits. Exceedance of the operating limits shall be considered credib le evidence of the exceedance of emission limits. Compliance with these emission limits may be determined as stated in Condition numbers III.A.6 through 11, III.B.4, I II.C.3, and III.D.1, and Table III.A.

Initial compliance with the lbs/MMBTU NO x limit shall be determined by performance testing as specified in 40 CF R 60.46b(e) using the continuous emissions monitoring system (CEMS) specified in Conditions III.B.4 and III.D.1. Continuing compliance with the lbs/MMBTU NO x limit shall be determined as specified in Condition III.B.4. Compliance to the NOx a nnual emission limit shall be determined by using the actual emission factor from pe rformance testing and CEMS results for the calculation of actual annual emissions as described in Condition III.C.3. (9 VAC 5-80-110, and Condition 10 of 6/04/07 NSR permit)

14. Requirements by Reference - Except where this permit is more restrictive than the applicable requirement, the boilers TS-E1 and TS-E2 shall be operated in compliance with the requirements of 40 CFR 60 Subpart Db. Note: All applicable requirements of 40 CFR 60, Subpart Db may not be specifically listed in this permit. The permittee should refer to the applicable regulation fo r additional requirements not included in this permit. (9 VAC 5-80-110, and Condition 14 of 6/04/07 NSR permit)

B. Monitoring

1. SO 2 and PM-10 Emissions Monitoring - Emissions of SO 2 and PM-10 from the combustion units FTSF-E1, FTSF-E2, 78-E1, 78-E2, 78-E3, 276-E1, 276-E2, 550-E8, 550-E9, 550-E13, and 1278-E1 shall be monitored by keeping records of throughput, type of fuel used, and appropriate data on fuel properties. The permittee shall calculate emissions of SO 2 and PM-10 in pounds per million BTU daily using daily fuel throughputs, fuel sulfur contents, and appropriate emission factors from the current AP-42. In lieu of a daily calculation, the permittee may make a one-time demonstration of maximum potential SO 2 and PM-10 emissions in pounds per million BTU using maximum fuel throughput, fuel su lfur content, and appropriate emission factors from AP-42, 5th Edition. The perm ittee shall maintain records of daily calculations for the most recent 5-year period. If the one-time maximum emission demonstration option is chosen, the permitt ee shall maintain a record of such aNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 30 demonstration for the life of the affected units. (9 VAC 5-80-110 B)

2. Visible Emission Evaluations - The permittee shall perform a visible emissions evaluation on the stack of boilers 78-E1, 78-E2, and 78-E3 once per month during daylight hours of operation for at least eighteen minutes in accordance EPA Method 9 (reference 40 CFR 60, Appendix A). If the VEE opacity average for the stack exceeds ten percent (10%), the VEE shall continue for one hour from initiation to determine compliance with the opacity limits . The permittee shall keep records in accordance with EPA Method 9 and maintain th e records at the facility for inspection by DEQ for the most recent 5-year period. (9 VAC 5-80-110 E)

3. Visible Emissions Observations - The permittee shall observe each stack of ovens/ furnaces 276-E1, 276-E2, 550-E8, 550-E9, 550-E13, and 1278-E1 for visible emissions for at least six minutes once per month during daylight hours of operation if the unit operates that month. If visibl e emissions are noted, corrective action shall be taken to eliminate the visible emissions . If visible emissions continue after corrective actions, a visible emissions evaluation (VEE) shall be immediately conducted on the stack for at least six mi nutes in accordance with Method 9 (40 CFR 60, Appendix A). If the VEE opacity average for the stack exceeds ten percent (10%), the VEE shall continue for one hour from initiation to determine compliance with the opacity limits. Results of observati ons and/or VEEs shall be recorded in the operation log. Records of observati ons shall include the following: The name of the observer, Date and time of the observation, An indication of presence or absence of visible emissions, The duration of any visible emission incident, and any corrective action to eliminate visible emissions. If a VEE is conducted, r ecords shall be in accordance with Method 9 (40 CFR 60, Appendix A). (9 VAC 5-80-110)

4. Continuous Emissions Moni toring Systems (CEMS)- The permittee shall install, calibrate, maintain, and operate a con tinuous monitoring system for measuring nitrogen oxides (NOx) emissions discharged to the atmosphere from each stack of boilers TS-E1 and TS-E2, and record the output of the system . The continuous monitoring system shall be operated and data recorded during all periods of operation of the boilers except for con tinuous monitoring system breakdowns and repairs. Data shall be recorded during calibration checks, and zero and span adjustments. The procedures under 40 CFR 60.13 shall be fo llowed for installation, evaluation, and operation of the continuous monitoring syst em. The span value for nitrogen oxides shall be set at 500 ppm. The 1-hour aver age NOx emission rates measured by the CEMS shall be expressed in lbs/MMBTU heat input and shall be used to calculate the average emission rates as specified in Condition III.A.13 on a 30- day rolling average basis. The 1-hour averages shall be calc ulated using the data points required under 40Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 31 CFR 60.13(b). At least two (2) data points must be used to calculate each 1-hour average. When NOx emission data are not obtained because of CEMS breakdowns, repairs, calibration checks, and zero and span adjustments, emission data will be obtained by using standby monitoring sy stems, Method 7, Method 7A, or other approved reference methods to provide emission data for a minimum of 75 percent of the operating hours in each steam generating unit operating day, in at least 22 out of 30 successive steam generating unit operating days. (9 VAC 5-80-110, and Condition 12 of 6/04/07 NSR permit)

5. Visible Emission Observations - The permittee shall observe each stack of boilers TS-E1 and TS-E2 at least once per week (Monday-Sunday) for visible emissions for at least twelve minutes duri ng daylight hours of operations if the unit operates that week. If visible emissions are noted from the stack for a duration of six minutes or more, operational adjustment or maintena nce shall be perfor med on the boiler to eliminate the visible emissions. If visi ble emissions continue after maintenance actions, a visible emissions evaluation (VEE) shall be immediately conducted on the stack for at least six minutes in accordan ce with Method 9 (40 CFR 60, Appendix A). If the VEE opacity average for the stack exceeds ten percent (10%), the VEE shall continue for one hour from initiation to dete rmine compliance with the opacity limit. Results of observations and/or VEEs shall be recorded in the operation log. Records of observations shall include the following: The name of the observer, Date and time of the observation, An indication of presence or absence of visible emissions, The color of the emissions, The duration of any visible em ission incident, and any co rrective action to eliminate visible emissions. If a VEE is conducted, reco rds shall be in accordance with Method 9 (40 CFR 60, Appendix A). (9 VAC 5-80-110, and Condition 13 of 6/04/07 NSR permit)

C. Recordkeeping

1. The permittee shall maintain records a ll No. 6 fuel oil shipments purchased, indicating sulfur content per shipment, a nd monthly fuel throughput records for Units FTSF-E1 and FTSF-E2 (combined) and Units FTSF-E1, FTSF-E2, 78-E1, 78-E2, and 78-E3 (combined). These records shall be ma intained at the facility for inspection by DEQ for the most recent 5-year period. (9 VAC 5-80-110 F)

2. The permittee shall maintain records of a ll required visible em issions evaluations and/or observations for Units 78-E1, 78-E2, 78-E3, 276-E1, 276-E2, 550-E8, 550-E9, 550-E13, and 1278-E1 and all required em ission calculations for Units FTSF-1, FTSF-2, 78-E1, 78-E2, 78-E3, 276-E1, 276-E2, 550-E8, 550-E9, 550-E13, and 1278- E1. These visible emissions evaluations a nd/or observations records and monthly emissions calculations shall be maintained at the facility for inspection by DEQ forNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 32 the most recent 5-year period. If a one-ti me emissions calculation is performed to demonstrate compliance with the SO2 and PM-10 limitations outlined in this section, the permittee shall maintain a record of such demonstration for the life of the affected units. (9 VAC 5-80-110 F)

3. The permittee shall maintain records of em ission data and operating parameters as necessary to demonstrate compliance with the permit for boilers TS-E1 and TS-E2. The content and format of such records sh all be arranged with the Tidewater Regional Office. These records shall include, but are not limited to:

a. Daily and annual throughput of distilla te oil. Annual throughput shall be calculated monthly as the sum of each consecutive 12-month period.

b. Monthly emissions calculations for NOx emissions from the boilers combined using NOx CEMS results and 140,000 BTU/gal distillate oil, or an alternative calculation method approved by the Tide water Regional Office to verify compliance with the tons/year emission lim itations. Annual emissions shall be calculated monthly as the sum of each consecutive 12-month period.

c. All fuel supplier certifications and all fuel receipts as described in 40 CFR 60.49b(r) which demonstrate that the oil meet s the definition of “very low sulfur oil” as defined in 40 CFR 60.41b.

d. Records of training and maintenance.

e. Records of all visible emission observa tions and visible emission evaluations.

f. Records of initial compliance perfor mance testing of NOx emissions.

g. Copies of all quarterly and semi-annual reports.

These records shall be available for inspection by the DEQ and shall be current for the most recent five (5) years. (9 VAC 5-80-110 and Condition 16 of 6/04/07 NSR permit)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 33

D. Testing

1. The boilers TS-E1 and TS-E2 shall be construc ted so as to allow for emissions testing upon reasonable notice at any time, using a ppropriate methods. Sampling ports shall be provided when requested at the appropria te locations and safe sampling platforms and access shall be provided. To determine initial compliance with the applicable lbs/MMBTU NOx limitation, the permittee shall conduct a performance test as required under 40 CFR 60.8 using the NOx continuous emissions monitoring systems (CEMS). For the initial compliance test, NOx from the boilers shall be monitored for 30 successive boiler operating days and th e 30-day average emission rate shall be used to determine compliance with th e lbs/MMBTU NOx emission limitation. The 30-day average emission rate shall be calculate d as the average of all hourly emission data recorded by the monitoring system during the 30-day test period. The permittee shall, upon request, determine complian ce with the lbs/MMBTU NOx limitation through the use of a 30-day pe rformance test as specified in 40 CFR 60.46b(e)(4). (9 VAC 5-80-110 and Condition 18 of 6/04/07 NSR permit)

2. If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approved by the DEQ. (9 VAC 5-80-110)

E. Reporting

1. Reporting Requirements - The permittee shall submit for the boilers TS-E1 and TSE2 the performance test data from the ini tial performance test specified in Condition III.D.1 and the performance evaluation of the CEMS using the applicable performance specifications found in Appendi x B of 40 CFR 60. The permittee shall submit quarterly excess emission reports for NOx (lbs/MMBTU) for any calendar quarter during which there are excess emissi ons from the boilers. If there are no excess emissions during the calendar quart er, the permittee shall submit a report semi-annually stating that no excess emissions occurred during the semi-annual reporting period. Excess emissions are defi ned as any calculat ed 30-day rolling average NOx emission rate as determined by Condition III.B.4 which exceeds the lbs/MMBTU NOx emission limitation in Condi tion III.A.13. The permittee shall also submit a NOx emission quarterly report cont aining the information specified in 40 CFR 60.49b(g). All quarterly reports specified in this condition shall be postmarked by the 30th day following the end of each ca lendar quarter. All semi-annual reports specified in this condition shall be post marked by the 30th day following the end of each calendar semi-annual period. One copy of each report shall be submitted to EPA at the following address:Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 34 Associate Director Office of Air Enforcement (3AP10) U.S. Environmental Protection Agency- Region III 1650 Arch Street Philadelphia, PA 19103-2029 (9 VAC 5-80-110, and Condition 15 of 6/04/07 NSR permit)

2. Semi-Annual Reports - The permittee shall submit for boilers TS-E1 and TS-E2 fuel quality reports to the Tidewater Regional O ffice within 30 days af ter the end of each semi-annual period. If no shipments of dis tillate oil were received during the semiannual period, the semi-annual report shall c onsist of the dates included in the semiannual period and a statement that no oil was received during the semi-annual period. If distillate oil was recei ved during the semi-annual peri od, the reports shall include:

a. Dates included in the semi-annual period,

b. A copy of all fuel supplier certifications and all fuel receipts for all shipments of distillate oil received during the se mi-annual period or a semi-annual summary from each fuel supplier that includes the information specified in Condition III.A.11 for each shipment of distillate oil, and

c. A signed statement from the owner or operato r of the facility th at the fuel supplier certifications or summaries of fuel supp lier certifications represent all of the distillate oil burned or received at the facility.

One copy of the semi-annual report shall be submitted to the U.S. Environmental Protection Agency at the addre ss specified in Condition III.E.1. (9 VAC 5-80-110 and Condition 17 of 6/04/07 NSR)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 35



### IV. Foundry Operation Requirements

A. Limitations

Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

550-E1 Argon/Oxygen Degassing Furnace (AOD) OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which

opacity shall not exceed 30%. These limits apply at

all times except during periods of startup, shutdown, or malfunction 9 VAC 5-50-80

550-E1 AOD PM 42.0 lbs/hour 9 VAC 5-40-2410
550-E2, 550-E3,

and
550-E4 Electric Arc Furnaces A, B, and C, respectively PM 0.005 grains/ dscf 40 CFR 63.7690 (a)(1)

550-EF1, 550-EF2, 550-EF5 Fugitive emissions from buildings 550 that house units that do not emit through a

conveyance Opacity Fugitive emissions shall not exhibit opacity greater than

20% (6-minute average) except for one 6-minute average per hour that does not exceed 27% opacity 40 CFR 63.7690 (a)(7)

550-E12 and 555-

EF3 Riser Burn Areas OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-2430 referencing 9 VAC 5-40-60 et seq.

550-E12 and 555-

EF3 Riser Burn Areas PM 3.05 lbs/hour 9 VAC 5-40-2410

555-E1 New Sand Operations OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-2430 referencing 9 VAC 5-40-60 et seq.

555-E1 New Sand Operations PM 42.0 lbs/hour 9 VAC 5-40-2410

555-E11 Sand Reclaim Operations OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-2430 referencing 9 VAC 5-40-60 et seq.

555-E11 Sand Reclaim Operations PM 27.0 lbs/hour 9 VAC 5-40-2410Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 36
Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

550-E20 Steel Shot Abrasive Blasting OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-2430 referencing 9 VAC 5-40-60 et seq.

550-E20 Steel Shot Abrasive Blasting PM 18.70 lbs/hour 9 VAC 5-40-2410

550-E21 Sawing Operation OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-2430 referencing 9 VAC 5-40-60 et seq.

550-E21 Sawing Operation PM 3.05 lbs/hour 9 VAC 5-40-2410

1. Emission Limits - Particulate emissions and visi ble emissions from the foundry operation units shall not exceed the limits specified in Table IV.A. (9 VAC 5-40-2410, 9 VAC 5-40-2430, and 9 VAC 5-80-110 B)

2. Emission Control - Particulate emissions from the Argon/Oxygen Degassing Furnace (AOD, Unit Ref. No. 550-E1) shall be cont rolled by a cartridge filter system (Unit Ref. No. 550-C1a). The cartr idge filter system shall be provided with adequate access for inspection and shall be in operation when the AOD is operating. (9 VAC 5-80-110)

3. Emission Control - Particulate emissions from the Electric Arc Furnaces (Unit Ref. No. 550-E2, 550-E3, and 550-E4) shall be c ontrolled by a cartridge filter system (Unit Ref. No. 550-C1a). The cartridge filte r system shall be provided with adequate access for inspection and shall be in oper ation when the furnace(s) is operating. (9 VAC 5-80-110 and 40 CFR 63.7690(c))

4. Emission Control - Particulate emissions from th e foundry operation Units Ref. No. 555-E1 and 555-E11 shall be controlled by fa bric filters (Unit Ref. No. 555-C1 and 555-C11, respectively). The fabr ic filters shall be provide d with adequate access for inspection and shall be in operati on when the unit(s) is operating. (9 VAC 5-80-110)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 37

B. Monitoring

1. Monitoring Device- Each filter (Unit Ref. No. 550-C1a, 555-C1, and 555-C11) shall be equipped with a device to continuous ly measure the differential pressure drop across the filter. The device shall be inst alled in an accessible location and shall be maintained by the permittee such that it is in proper working order at all times. (9 VAC 5-80-110, 40 CFR 64.2, and 40 CFR 63 Subpart EEEEE)

2. Monitoring Device- The cartridge filter system (Un it Ref. No. 550-C1a) shall be equipped with a bag leak detection system. The monitoring device shall be installed, maintained, calibrated and operated in accordance with approved procedures which shall include, as a minimum, the manufacturer's written requirements or recommendations. The monitoring device sha ll be provided with adequate access for inspection and shall be in operation wh en the foundry furnace(s) is operating. (9 VAC 5-80-110, 40 CFR 64.2, and 40 CFR 63 Subpart EEEEE)

3. Visible Emission Evaluations - The permittee shall perform a visible emissions evaluation on the stack of the Argon/ Oxygen Degassing Unit (Stack 550-S1) once every six months during daylight hour s of operation utilizing EPA Method 9 (reference 40 CFR 60, Appendix A). The pe rmittee shall keep records in accordance with EPA Method 9 and maintain the records at the facility for inspection by DEQ for the most recent 5-year period. (9 VAC 5-80-110 E)

4. Visible Emission Observations - The permittee shall observe stack emissions of unit 550-E20 at least once per month during da ylight hours of operations for visible emissions for at least six mi nutes. If visible emissions are noted from the stack, operational adjustment or maintenance shal l be performed to eliminate the visible emissions. If visible emissions conti nue after maintenance actions, a visible emissions evaluation (VEE) shall be immedi ately conducted on the stack for at least six minutes in accordance with Method 9 (40 CFR 60, Appendix A). If the VEE opacity average for the stack exceeds ten pe rcent (10%), the VEE shall continue for one hour from initiation to determine complia nce with the opacity limit. Results of observations and/or VEEs shall be reco rded in the operation log. Records of observations shall include the following: The name of the observer, Date and time of the observation, An indication of presence or absence of visible emissions, The color of the emissions, The duration of any visible em ission incident, and any co rrective action to eliminate visible emissions. If a VEE is conducted, reco rds shall be in accordance with Method 9 (40 CFR 60, Appendix A). (9 VAC 5-80-110)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 38 5. Compliance Assurance Monitoring (CAM) for the Argon/Oxygen Degassing Furnace (Unit Ref. No. 550-E1)- The permittee shall monitor, operate, calibrate and maintain the cartridge filter system (550-C1a) controlling the Argon/ Oxygen Degassing furnace (Unit Ref. No. 55 0-E1) according to the following:

Monitoring, Frequency, Records Performance Criteria Indicator Range; Averaging Period Indicator 1 : Cartridge Leak Detection System (CLDS)- The cartridge filter system is equipped with a continuous PM monitor which detects cartridge failures as a result of increased PM emissions. The monitor has continuous readout of PM emissions (one reading at least every 15 seconds). Each reading is collected and recorded by a Data Logger. Monthly Response Tests and Electronic Drift Checks will be done. Recorder data will be backed up quarterly . On an annual basis the monitor settings will be readjusted following the procedures listed in the Monitor Set up procedures. The sensor probe will be removed and any material build up on the probe will be removed using a dry cloth. The insulator between the duct and the probe will be inspected for any material build up that could form a conductive electrical bridge across the insulator increasing signal strength and resulting in a false high alarm. The insulator will be cleaned as necessary and reinstalled insuring the inner surface is flush with or slightly protruding from the inner wall to prevent a pocket. The cartridge leak indication alarm will be set at approximately two (2) times the maximum height of a typical cleaning spike, or four (4) times the typical average reading during normal operation. A high level alarm is triggered if the CLDS PM monitor reading exceeds the high level set point for more than 30 seconds. An excursion is defined as triggering a high level alarm. Five (5) excursions during five (5) separate melt periods in any semiannual reporting period will trigger a Quality Improvement Plan (QIP).Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 39

Indicator 2 : PressureDropPressure drop across each of the East and West cartridge filter systems (2 separate units) shall be monitored continuously to verify that the pressure drop is within manufacturer's specifications. The monitor has continuous readout of pressure drop (one reading at least every 15 seconds). Each reading is collected and recorded by a Data Logger. Before beginning each melt cycle, conduct visual inspection to ensure pressure gauges are not broken (physically). Visually inspect outside of dust collectors for broken mounting bolts and/or holes in sheet metal walls. Ensure electrical conduit and pneumatic valves are not corroded, crimped or have restricted air flow. Inspect dust collection bags. If over 2/3 full, schedule for replacement. The pressure drop should read between nominal 2 and 3 inches of water pressure. If over 3 and less than 6 inches, start a cleaning cycle. If over 6, change filters. A high level alarm set point is established at 4 inches to provide advance warning of, and opportunity to correct, excessive pressure drop. A high level alarm is triggered if the pressure drop exceeds the high level set point. An excursion is defined as a pressure reading over 6 inches. Two (2) excursions at a cartridge filter unit in any semiannual reporting period will trigger a Quality Improvement Plan (QIP).

6. Compliance Assurance Monitoring (CAM ) for the New Sand Operation (Unit Ref. No. 555-E1) and the Sand Reclai m Operation (Unit Ref. No. 555-E11) - The permittee shall monitor, operate, calibrate and maintain each of the Building 555 fabric filters (Unit Reference No. 555-C1 and 555-C11) controlling the New Sand Operation and the Sand R eclaim Operation (Unit Ref. No. 555-E1 and 555-E11, respectively), according to the following:Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 40

Monitoring, Frequency, Records Performance Criteria Indicator Range; Averaging Period Indicator 1 : PressureDropPressure drop across the fabric filters shall be read at least once per day at start-up prior to sand silo filling or sand reclamation. The value shall be recorded in the operation log. Once per day of sand operations, operate the system fan and verify that the pressure gauge responds and that the reading is within the appropriate range. Conduct visual inspection to ensure pressure gauges are not broken (physically). Visually inspect outside of dust collectors for broken mounting bolts and/or holes in sheet metal walls. Inspect dust collection containers. If over 2/3 full, schedule for replacement. Gauge should read between 1 and 3 inches of pressure. If outside of range, inspect for bag failure or plugging. An excursion is defined as a reading less than 1 inch or over 3 inches during sand silo filling or sand reclamation. Five (5) excursions in any semiannual reporting period will trigger a Quality Improvement Plan (QIP). Indicator 2 : BagConditionAnnual inspection of bag material and support structure conditions and replacement of bags if necessary. Results shall be recorded in inspection/ maintenance log. Trained personnel perform the inspections and maintenance. Bags are inspected visually for deterioration to determine bag condition and remaining life. An excursion is defined as a failure to perform the annual inspection within 12 months from the last one. An excursion shall trigger an inspection, corrective action, and a reporting requirement. Two consecutive excursions will trigger a Quality Improvement Plan (QIP).

7. Compliance Assurance Monitoring (CAM) - The permittee shall conduct the monitoring and fulfill the other obligations specified in 40 CFR 64.7 through 40 CFR 64.9. (9 VAC 5-80-110 E and 40 CFR 64.6 (c))

8. Compliance Assurance Monitoring (CAM) - At all times, the permittee shall maintain the monitoring equipment, in cluding, but not limited to, maintaining necessary parts for routine repair s of the monitoring equipment. (9 VAC 5-80-110 E and 40 CFR 64.7 (b))Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 41

9. Compliance Assurance Monitoring (CAM) - Except for, as applicable, monitoring malfunctions, associated repairs, and require d quality assurance or control activities (including, as applicable, calibration checks and required zero and span adjustments), the permittee shall conduct all monitoring in continuous operation (or shall collect data at all required interv als) at all times that the Argon/Oxygen Degassing Furnace (Unit Ref. No. 550-E1), the New Sand Opera tion (Unit Reference No. 555-E1), or the Sand Reclaim Operation (Unit Ref. No. 555-E 11) is operating. Data recorded during monitoring malfunctions, associat ed repairs, and required qu ality assurance or control activities shall not be us ed for purposes of compliance assurance monitoring, including data averages and calculations, or fulfilling a minimum data availability requirement, if applicable. The permittee sh all use all the data collected during all other periods in assessing the operation of the control device and associated control system. A monitoring malfunction is a ny sudden, infrequent, not reasonably preventable failure of the monitoring to pr ovide valid data. Monitoring failures that are caused in part by inadequate main tenance or improper operation are not malfunctions. (9 VAC 5-80-110 E and 40 CFR 64.7 (c))

10. Compliance Assurance Monitoring (CAM) - Upon detecting an excursion or exceedance, the permittee shall restore operation of the Argon/Oxygen Degassing Furnace (Unit Ref. No. 550-E1), the New Sand Operation (Unit Reference No. 555- E1), or the Sand Reclaim Operation (Unit Ref. No. 555-E11) (i ncluding the control device and associated capture system) to it s normal or usual manner of operation as expeditiously as practicable in accordan ce with good air polluti on control practices for minimizing emissions. The response sh all include minimizing the period of any startup, shutdown or malfunction and taki ng any necessary corrective actions to restore normal operation and prevent the li kely recurrence of the cause of an excursion or exceedance (other than t hose caused by excused startup and shutdown conditions). Such actions may include in itial inspection and evaluation, recording that operations returned to normal without operator action (such as through response by a computerized distribution control system ), or any necessary follow-up actions to return operation to within the indicator, designated condition, or below the applicable emission limitation or standard, as applicable. (9 VAC 5-80-110 E and 40 CFR 64.7 (d)(1))

11. Compliance Assurance Monitoring (CAM) - Determination that acceptable procedures were used in response to an excursion or exceedance will be based on information available, which may include but is not limited to, monitoring results, review of operation and maintenance proce dures and records, a nd inspection of the control device, associated capture system, and the process. (9 VAC 5-80-110 E and 40 CFR 64.7(d)(2))Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 42 12. Compliance Assurance Monitoring (CAM) - If the permittee identifies a failure to achieve compliance with an emission limita tion or standard for which the approved monitoring did not provide an indicati on of an excursion or exceedance while providing valid data, or the results of comp liance or performance testing document a need to modify the existing indicator ra nges or designated conditions, the permittee shall promptly notify the Director, Tide water Regional Office and, if necessary, submit a proposed modification to this pe rmit to address the necessary monitoring changes. Such a modification may incl ude, but is not limited to, reestablishing indicator ranges or designated conditi ons, modifying the frequency of conducting monitoring and collecting data, or the monitoring of additional parameters. (9 VAC 5-80-110 E and 40 CFR 64.7(e))

13. Compliance Assurance Monitoring (CAM) - If the number of excursions exceeds the threshold set for the Argon/Oxygen Degassing Furnace (Unit Ref. No. 550-E1), the New Sand Operation (Unit Referen ce No. 555-E1), or the Sand Reclaim Operation (Unit Ref. No. 555-E11) in any semiannual reporting period, the permittee shall develop, implement and maintain a Quality Improvement Plan (QIP) in accordance with 40 CFR 64.8. If a QIP is required, the permittee shall have it available for inspection. The QIP initially shall include procedures for evaluating the control performance problems and, based on th e results of the ev aluation procedures, the permittee shall modify the plan to include procedures for conducting one or more of the following, as appropriate:

a. Improved preventative maintenance practices;

b. Process operation changes;

c. Appropriate improvements to control methods;

d. Other steps appropriate to corre ct control performance; and

e. More frequent or improved monitoring. (9 VAC 5-80-110 E and 40 CFR 64.8(a) and (b))

14. Requirements by Reference - Except where this permit is more restrictive than the applicable requirement, the Foundry Operati on shall be operated in compliance with the requirements of 40 CFR 63 Subpart EEEEE. Note: All applicable requirements of 40 CFR 63, Subpart EEEEE may not be specifically listed in this permit. The permittee should refer to the applicable regulation for additional requirements not included in this permit. (9 VAC 5-80-110)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 43

15. Work Practice Standards - The permittee must prepare and operates at all times according to a written certif ication that the foundry purch ases and uses only metal ingots, pig iron, slitter, or other mate rials that do not include post-consumer automotive body scrap, post-consumer engine blocks, post-consumer oil filters, oily turnings, lead components, mercury switche s, plastics, or free organic liquids. (9 VAC 5-80-110 and 40 CFR 63.7700(b))

16. Initial Compliance Demonstration - The permittee must demonstrate initial compliance to the work practice standard s in 40 CFR 63.7700(b) within 30 calendar days after the compliance date speci fied in 40 CFR 63.7683(b) (April 22, 2005). (9 VAC 5-80-110 and 40 CFR 63.7730(b))

17. Operations and Maintenance Requirements - The permittee must prepare and operate at all times according to a writte n operation and maintenance plan (O&M Plan) for each capture and collection system and control device for the Electric Arc Furnaces (Unit Ref. No. 550-E2, 550-E3, and 550-E4) that are subject to the emission limit in 40 CFR 63.7690(a). Your O& M Plan is subject to approval by the Director, Tidewater Regional Office, and mu st contain elements described in 40 CFR 63.7710 (b)(1) through (6). Applicable requ irements are including, but not limited to, the following:

a. Monthly inspections of the equipment that is important to the performance of the total capture system (i.e., pressure sensors, dampers, and damper switches) (40 CFR 63.7710 (b)(1)).

b. Preventive maintenance plan for each control device, incl uding a preventive maintenance schedule that is consistent with the manufa cturer’s instructions for routine and long-term mainte nance (40 CFR 63.7710 (b)(3)).

c. A site specific monitoring plan for ea ch bag leak detection system (40 CFR 63.7710(b)(4)).

d. Corrective action plan for the cartri dge filter system (40 CFR 63.7710(b)(5)).

e. Procedures for providing an ignition sour ce to mold vents of sand mold systems in each pouring area and pouring station unl ess it has been determined that the mold vent gases either are not ignitable, ignite automa tically, or cannot be ignited due to accessibility or safety issues. This determination must be documented and records are maintained (40 CFR 63 7710(b)(6)).

(9 VAC 5-80-110 and 40 CFR 63.7710(b))Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 44

18. Initial Compliance Demonstration - For each O&M Plan requirement where initial compliance is not demonstrated using a performance test, the permittee must demonstrate initial compliance within 30 calendar days after the compliance date specified in 40 CFR 63. 7683(b) (April 23, 2007). (9 VAC 5-80-110 and 40 CFR 63.7730(b))

19. Startup, Shutdown, and Malfunction Plan - The permittee must develop a written startup, shutdown, and malfunction plan for th e electric arc furnaces (Unit Ref. No. 550-E2, 550-E3, and 550-E4) according to the provisions in 40 CFR 63.6 (e)(3). (9 VAC 5-80-110 and 40 CFR 63.7720(c))

20. Continuing Monitoring Requirements - For the cartridge filter system, the permittee must at all times monitor the relative change in PM loading using a bag leak detection system according to the requirements in 40 CFR 63.7741(b) and conduct inspections at their specified frequencies according to the requirements specified in 40 CFR 63.7740(c)(1) through (8), as applicable. (9 VAC 5-80-110 and 40 CFR 63.7740(c))

21. Monitoring Device Requirements - The cartridge filter system shall be equipped with a bag leak detection system that mu st be installed, operated, and maintained according to the requirements in 40 CFR 63.7741(b), including, but not limited to, the following:

a. The system must be certified by the manuf acturer to be capable of detecting PM emissions at concentrations of 0.0044 grai ns per actual cubic foot or less.

b. The bag leak detection system sensor mu st provide output of relative particulate matter loadings and continuously record the output with a data logger.

c. The system must be equipped with an al arm that will sound when an increase in relative particulate loading is detected ove r the alarm set point established in the O&M Plan, and the alarm must be locat ed such that it can be heard by the appropriate plant personnel.

d. The initial adjustment of the system must , at minimum, consist of establishing the baseline output by adjusting the sensitivity (range) and the averaging period of the device, and establishing the alarm se t points and the alarm delay time (if applicable)

e. Following the initial adjustment, the sensit ivity or range, averaging period, alarm set point, or alarm delay time should not be adjusted without the approval of the Director, Tidewater Regional Office. Excep t, once per quarter, the sensitivity of the bag leak detection system may be adjusted to account for seasonal effects including temperature and humidity accordi ng to the procedures in the O&M Plan required by 40 CFR 63.7710(b).Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 45 f. The bag leak detector sensor shall be installed downstream of the cartridge filter.

g. Where multiple detectors are required, th e system's instrumentation and alarm may be shared among detectors.

(9 VAC 5-80-110 and 40 CFR 63.7741(b))

C. Recordkeeping

1. The permittee shall maintain records of a ll emission data and operating parameters necessary to demonstrate compliance with th is permit. The content and format of such records shall be arranged with the Di rector, Tidewater Regional Office. These records shall include, but are not limited to:

a. Pressure drop monitoring records.

b. Visible emission observations, and if V EE is performed, records in accordance with Method 9 (40 CFR 60 Appendix B).

c. Visible emission evaluation records in accordance with Method 9 (40 CFR 60 Appendix B)

d. Total annual throughput of steel scrap fo r the foundry, calculated monthly as the sum of each consecutive 12-month period.

e. Copies of all required notifications.

f. Copies of all required reports.

g. All required opacity and PM performance test results.

h. Records specified in 40 CFR 63.6(e)(3)(ii i) through (v) re lated to startup, shutdown, and malfunction.

i. Records of the times the cartridge leak detection system alarm sounded, and for each valid alarm, the time you initiated corrective action, th e corrective action taken, and the date on which corrective action was completed (40 CFR 63.7743(c)(2)).

j. Records of all inspections and maintenan ce of the cartridge filter system as required by 40 CFR 63.7740(c), including al l information needed to document conformance with these requirements (40 CFR 63.7743(c)(1)).

k. Records that document continuous complian ce with the work practice standards in 40 CFR 63.7700(b) ( 40 CFR 63.7744(a)).Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 46 l. Records of monthly inspections, preventiv e maintenance, site-specific bag leak detection system monitori ng, and corrective action to document conformance with the requirements of the O&M Plan (40 CFR 63.7745(a))

m. A current copy of the O&M Plan shall be available for inspection upon request. The plans must be kept for the life of the foundry or until the foundry is no longer subject to the requirements of 40 CFR 63 Subpart EEEEE (40 CFR 63.7745(b)).

These records shall be available on site for inspection by the DEQ and shall be current for the most recent five (5) years unless otherwise noted. (9 VAC 5-80-110 and 40 CFR 63.7752)

2. Compliance Assurance Monitoring (CAM) Recordkeeping - The permittee shall maintain records of monitoring data, mon itor performance data, corrective actions taken, any written quality improvement plan (QIP) required pursuant to §64.8 and any activities undertaken to implement a quali ty improvement plan (QIP), and other supporting information required to be maintained under this part (suc h as data used to document the adequacy of monitoring, or records of monito ring maintenance or corrective actions). (9 VAC 5-80-110 E and 40 CFR 64.9(b))

D. Testing

1. Initial Performance Tests - The permittee must conduct performance tests no later than 180 calendar days after the complianc e date specified in 40 CFR 63.7683 (April 23, 2007) to demonstrate initial compliance w ith each applicable emission limitation in 40 CFR 63.7690, including the PM emission limit in 40 CFR 63.7690(a)(1) for the electric arc furnaces (550-E2 through E4) and the fugitive opacity limits in 40 CFR 63.7690(a)(7). (9 VAC 5-80-110 and 40 CFR 63.7730(a))

2. Subsequent Performance Tests - The permittee must conduct subsequent performance tests to demonstrate compliance with the applicable PM emission limit in 40 CFR 63.7690(a)(1) for the electric ar c furnaces (550-E2 through E4) in no less frequently than every 5 years. (9 VAC 5-80-110 and 40 CFR 63.7731(a))

3. Subsequent Performance Tests - The permittee must conduct subsequent performance tests to demonstrate complian ce with the applicable fugitive emission opacity limits in 40 CFR 63.7690(a)(7) no less frequently than once every 6 months (a subsequent performance test is consider ed timely if conducted anytime within the sixth calendar month following the m onth the previous test was conducted). (9 VAC 5-80-110 and 40 CFR 63.7731(b))

4. Test Method - To determine compliance with the applicable PM emission limit in 40 CFR 63.7690(a)(1) for the electric arc furnaces, the test methods and procedures in 40Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 47 CFR 63.7732(b) shall be followed. (9 VAC 5-80-110 and 40 CFR 63.7732(b))

5. Test Method - To determine compliance with the opacity limit in 40 CFR 63.7690(a)(7) for fugitive emissions from buildings or structures housing any emission units of the foundry operation, EPA Method 9 (reference 40 CFR 60 Appendix A) shall be conducted by a certified observer, and conc urrently with the PM performance tests, as required by 40 CFR 63.7732(d). (9 VAC 5-80-110 and 40 CFR 63.7732(d))

6. Initial Compliance Demonstration - Initial compliance with the applicable emission limitations in 40 CFR 63.7690(a) is demonstrated if:

a. The average PM concentration in the e xhaust stream, determined according to 40 CFR 63.7732(b), did not exceed 0.005 grains/dscf, andNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 48

b. For each building or structure housing any emission units of the foundry operation, the opacity of fugitive emissi ons discharged to the atmosphere, determined according to 40 CFR 63.7732(d) , did not exceed 20 percent (6-minute averages), except for one 6-minute averag e per hour that did not exceed 27 percent opacity.

(9 VAC 5-80-110, 40 CFR 63.7734(a)(1 )(i) and 40 CFR 63.7734(a)(7))

7. Initial Compliance Demonstration - Initial compliance with the applicable work practice standards in 40 CFR 63.7700(b) is demonstrated if the permittee has certified in the Notification of Compliance Status that: “At all times, the foundry will purchase and use only metal ingots, pig iron, slitter, or other ma terials that do notinclude post-consumer automotive body scrap, post-consumer engine blocks, postconsumer oil filters, oily tu rnings, lead components, mercury switches, plastics, or free organic liquids”. (9 VAC 5-80-110 and 40 CFR 63.7735(a))

8. Initial Compliance Determination - Initial compliance with the applicable operation and maintenance requirements for each bag leak detection system is demonstrated if the permittee has certified in the Notification of Compliance Status that:

a. The bag leak detection system monitoring plan has been submitted to the Director, Tidewater Regional Office for a pproval according to the requirements of 40 CFR 63.7710(b);

b. Each bag leak detection system shall be inspected, operated, and maintained according to the procedures in the O&M Plan;

c. Corrective action procedures for bag leak detection system alarms shall be followed according to the re quirements of the O&M Plan;

d. The mold vent ignition plan has been submitted to the Director, Tidewater Regional Office for approval according to the requirements of 40 CFR 63.7710(b); and

e. The procedures for igniting mold vent gases shall be followed according to the requirements of the O&M Plan.

(VAC 5-80-110 and 40 CFR 63.7736(c) and (d))

9. The permitted facility shall be constructed so as to allow for emissions testing at any time using appropriate methods. Upon request from the Department, test ports shall be provided at the a ppropriate locations. (9 VAC 5-40-30, 9 VAC 5-50-30, and 9 VAC 5-80-110)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 49 10. If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approved by the DEQ. (9 VAC 5-80-110)

E. Notifications and Reporting

1. Notification Requiremen ts (40 CFR 63 Subpart EEEEE) - The permittee shall furnish written notification to the Director, Tidewater Regional Office:

a. All notifications required by 40 CFR 63.6(h )(4) and (5), 63.7(b) and (c), 63.8(e), 63.8(f)(4) and (6), 63.9(b) through (h), as applicable, by the specified dates.

b. The initial notification of applicability of 40 CFR Subpart EEEEE no later than August 20, 2004 (40 CFR 63.7750(b)).

c. The anticipated date of performance test s post-marked at le ast 60 calendar days prior to such date (40 CFR 63.7750(d)).

d. Notification of compliance status post-ma rked no later than 30 calendar days following each compliance demonstration that does not require a performance test (40 CFR 63. 63.7750(e)(1).

e. Notification of compliance status post-ma rked no later than 60 calendar days following each compliance demonstration that requires a performance test (40 CFR 63. 63.7750(e)(2)).

(9 VAC 5-80-110 and 40 CFR 63.7750)

2. Semiannual Compliance Report s (40 CFR 63 Subpart EEEEE)- The permittee shall submit semiannual compliance reports to the Director, Tidewater Regional Office, postmarked no later than January 31 or July 31, covering reporting periods from July 1 through December 31, and Janua ry 1 through June 30, respectively. The reports shall include informati on specified in 40 CFR 63.7751(b). (9 VAC 5-80-110 and 40 CFR 63.7751(a) and (b))

3. Startup, Shutdown, and Malfunction Report (40 CFR 63 Subpart EEEEE)- If a startup, shutdown, or malfunction occurs that was not consistent with the SSM Plan, the permittee must submit an immediate startup, shutdown, and malfunction report according to the requirements of 40 CFR 63.10(d)(5)(ii). (9 VAC 5-80-110 and 40 CFR 63.7751(c))

4. Deviation Report (40 CFR 63 Subpart EEEEE) - The permittee shall report deviations as defined in 40 CFR 63 Subpart EEEEE as part of the Title V semiannual monitoring reports required by General Condition XIV.C.3 of this permit. (9 VAC 5-80-110 and 40 CFR 63.7751(d))Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 50 5. Compliance Assurance Monitoring (CAM) Reporting - The permittee shall submit CAM reports as part of the Title V semi-annual monitoring reports required by General Condition XIV.C.3 of this permit to the Director, Tidewater Regional Office. Such reports shall include at a minimum:

a. Summary information on the number, duration and cause (including unknown cause, if applicable) of excursions or exceedances, as applicable, and the corrective actions taken;

b. Summary information on the number, duration and cause (including unknown cause, if applicable) for monitor down time incidents (other than downtime associated with zero and span or other da ily calibration checks, if applicable); and

c. A description of the actions taken to implement a quali ty improvement plan (QIP) during the reporting period as specified in §64.8. Upon completion of a QIP, the owner or operator shall incl ude in the next summary repo rt documentation that the implementation of the plan has been co mpleted and reduced the likelihood of similar levels of excursions or exceedances occurring. (9 VAC 5-80-110 F and 40 CFR 64.9(a))



### V. Steel Preparation and Fabrication Requirements

A. Limitations

Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/Emission Limit/Standard/Work Practice Citation

1746-E1 Abrasive Blasting/ Steel Shot PM 7.58 lbs/hour 9 VAC 5-40-260

1746-E1 Abrasive Blasting/ Steel Shot Opacity Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-320 referencing 9 VAC 5-40-60 et seq.

274-E1,

and
275-E5 Abrasive Shot Blasting PM 7.58 lbs/hour each 9 VAC 5-40-260

274-E1, and 275- E5 Abrasive Shot Blasting Opacity Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-320 referencing 9 VAC 5-40-60 et seq.

276-E3 Wire Brush Paint Removal PM Exempt 9 VAC 5-40-260Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 51
Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/Emission Limit/Standard/Work Practice Citation

276-E3 Wire Brush Paint Removal Opacity Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-320 referencing 9 VAC 5-40-60 et seq.

276-E3PC Plasma Cutting PM Exempt 9 VAC 5-40-260 276-E3PC Plasma Cutting Opacity Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-320 referencing 9 VAC 5-40-60 et seq.

288-E1 through

E4 Abrasive Blasting PM 7.58 lbs/hour each 9 VAC 5-40-260

288-E1 through

E4 Abrasive Blasting Opacity Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-320 referencing 9 VAC 5-40-60 et seq.

1. Emission Limitations - Particulate emissions and visi ble emissions from each of the units in Steel Preparation and Fabrication shall not exceed the limitations specified in Table V.A. (9 VAC 5-80-110 B)

B. Monitoring

1. Visible Emission Observations - The permittee shall perform a visible emissions evaluation on the stack of each unit in Table V.A at least once per month during daylight hours of operation for at least eighteen minutes in accordance EPA Method 9 (reference 40 CFR 60, Appendix A). If the VEE opacity average for the stack exceeds ten percent (10%), the VEE shall continue for one hour from initiation to determine compliance with the opacity limits . The permittee shall keep records in accordance with EPA Method 9 and maintain th e records at the facility for inspection by DEQ for the most recent 5-year period. (9 VAC 5-80-110 E)

C. Recordkeeping

1. The permittee shall maintain records of a ll emission data and operating parameters necessary to demonstrate compliance with th is permit. The content and format of such records shall be arranged with the Di rector, Tidewater Regional Office. These records shall include, but are not limited to:

a. Annual throughput of abrasive blast medi a (in tons) and hours of operation for each of the Steel Preparation and Fabrication Operations ac tivities listed in TableNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 52 V.A. The abrasive blast media throu ghput (in tons) and hour s of operation shall be recorded and maintained in a log book for each calendar month such that the annual amounts can be calculated monthl y as the sum of each consecutive 12- month period.

b. Visible emission evaluations (VEE) reco rds in accordance with Method 9 (40 CFR 60 Appendix B). These records shall be available on site for inspection by the DEQ and shall be current for the most recent five (5) years.
(9 VAC 5-80-110)

D. Testing

1. If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approved by the DEQ. (9 VAC 5-80-110)



### VI. Secondary Lead Processing Requirements

A. Limitations

Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

4582-E1 through E6, 4582- E12, and

LS-E1 Secondary Lead Processing Units, combined PM 0.6 lbs/hour and 2.4 tons/year Condition 3 of 12/16/81 NSR permit

4582-E1 through E6, 4582- E12, and

LS-E1 Secondary Lead Processing Units, combined LEAD 0.2 lbs/hour and 0.9 tons/year Condition 4 of 12/16/81 NSR permit

4582-E1 through E6, 4582- E12, and

LS-E1 Secondary Lead Processing Units, each stack OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 30%. 9 VAC 5-50-80, and 12/16/81 NSR permit

1. Emission Control - Particulate and lead emissions from Secondary Lead Processing shall be controlled by baghouse filters. Th e baghouse filters shall be provided with adequate access for inspection. (9 VAC 5-80-110, and 12/16/81 NSR permit)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 53 2. Throughput Limit - The annual throughput of lead in the Secondary Lead Processing operations shall not exceed 1,500 tons per ye ar, calculated monthly as the sum of each consecutive 12-month period. (9 VAC 5-80-110 and Condition 2 of 12/16/81 permit)

3. Emission Limits - Emissions from Secondary Lead Processing shall not exceed the limitations specified in Table VI.A. (9 VAC 5-80-110, 9 VAC 5-50-80, and Conditions 3 and 4 of 12/16/81 NSR permit)

4. Operating and Training Procedures - Secondary lead process emissions shall be controlled by proper operation and mainte nance of the air pollution control equipment. Operators shall be trained and certified in the proper operation of all such equipment. The permittee shall have avai lable good written opera ting procedures and a maintenance schedule for all such equipm ent. These procedures shall be based on manufacturer’s recommendations, at minimum. (9 VAC 5-80-110, and Conditions 6 and 7 of 12/16/81 NSR permit)

B. Monitoring

1. Lead Throughput Monitoring - The permittee shall monitor the throughput of lead (in tons) processed on a monthly basis and re cord the monthly throughput of lead in a logbook to be maintained at the facility fo r inspection by DEQ for the most recent 5- year period. (9 VAC 5-80-110 E)

2. Visible Emission Observations - The permittee shall observe each stack of emission units in Table VI.A at least once per w eek (Monday through Sunday) during daylight hours of operations for visible emissions for at least 6 minutes. If visible emissions are noted from the stack, operational adjustme nt or maintenance shall be performed to eliminate the visible emissions. If visi ble emissions continue after maintenance actions, a visible emissions evaluation (VEE) shall be immediately conducted on the stack for at least six minutes in accordan ce with Method 9 (40 CFR 60, Appendix A). If the VEE opacity average for the stack exceeds ten percent (10%), the VEE shall continue for one hour from initiation to dete rmine compliance with the opacity limit. Results of observations and/or VEEs shall be recorded in the operation log. Records of observations shall include the following: The name of the observer, Date and time of the observation, An indication of presence or absence of visible emissions, The color of the emissions, The duration of any visible em ission incident, and any co rrective action to eliminate visible emissions. If a VEE is conducted, reco rds shall be in accordance with Method 9 (40 CFR 60, Appendix A). (9 VAC 5-80-110)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 54 C. Recordkeeping

1. The permittee shall maintain records of a ll emission data and operating parameters necessary to demonstrate compliance with th is permit. The content and format of such records shall be arranged with the Di rector, Tidewater Regional Office. These records shall include, but are not limited to:

a. Annual throughput of lead in tons for the Secondary Lead Processing operation, calculated monthly as the sum of each c onsecutive twelve (12) month period.

b. Operator training and certification records.

c. Pollution control equipment maintenance records.

d. Weekly visible emission s observations, visible em issions evaluations (if performed), and any corrective action.

These records shall be available on site for inspection by the DEQ and shall be current for the most recent five (5) years.
(9 VAC 5-80-110, and Conditions 6 and 7 of 12/16/81 NSR Permit)

D. Testing

1. If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approved by the DEQ. (9 VAC 5-80-110)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 55



### VII. Woodworking

A. Limitations

Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

3-E1 Cutting/Planer/Re-saw PM 0.05 grains per standard cubic foot of exhaust gas 9 VAC 5-40-2270 B

3-E1 Cutting/Plan er/Re-saw OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-2280 referencing 9 VAC 5-40-60 et seq.

501-E2 Foundry Pattern Shop - wood cutting machines PM 0.05 grains per standard cubic foot of exhaust gas 9 VAC 5-40-2270 B

501-E2 Foundry Pattern Shop - wood cutting machines OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-2280 referencing 9 VAC 5-40-60 et seq.

513-E1 Warehouse No. 6 Saws PM 0.05 grains per standard cubic foot of exhaust gas 9 VAC 5-40-2270 B

513-E1 Warehouse No. 6 Saws OPACITY Opacity limited to 20% except for one 6-minute period in each hour in which opacity shall not exceed 60% 9 VAC 5-40-2280 referencing 9 VAC 5-40-60 et seq.

1. Emission Limits - Emissions from Woodworking Oper ations shall not exceed the limitations specified in Table VII.A. Co mpliance shall be based on compliance with the monitoring and recordkeeping provisions of this section. (9 VAC 5-40-2270, 9 VAC 5-40-2280, and 9 VAC 5-80-110)

2. Emission Control - Particulate emissions from W oodworking Operations shall be controlled by the use of cyclones. The cy clones shall be provided with adequate access for inspection and shall be in op eration when the process is operating. (9 VAC 5-40-2270 and 9 VAC 5-80-110)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 56

B. Monitoring

1. Visible Emissions Observations - The permittee shall observe the stacks of emission units in Woodworking Operations for at least 6 minutes once per week (Monday through Sunday) during daylight hours of ope ration for visible emissions. Lack of visible emissions shall indicate complianc e with the provisio ns of 9 VAC 5-40- 2270.B. If any visible emissions are noted, the permittee shall take corrective action and document the visible emissions incident in a log book. Records of observations shall include the following: The name of the observer, Date and time of the observation, An indication of presence or ab sence of visible emissions, and Any corrective action to eliminate visible emissions. (9 VAC 5-80-110)

2. The permittee shall inspect the cyclones on ce per month for struct ural integrity and record the results in a logbook. (9 VAC 5-80-110)

C. Recordkeeping

1. The permittee shall maintain records of a ll emission data and operating parameters necessary to demonstrate compliance with th is permit. The content and format of such records shall be arranged with the Di rector, Tidewater Regional Office. These records shall include, but are not limited to:

a. All visible emissions observations and corrective action.

b. All cyclone structural integrity evaluations.

These records shall be available on site for inspection by the DEQ and shall be current for the most recent five (5) years. (9 VAC 5-80-110)

D. Testing

1. If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approved by the DEQ. (9 VAC 5-80-110)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 57



### VIII. Electroplating Operations

A. Limitations

Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

PLATE-E1 PLATE-E2
PLATE-E3 Three (3) chromium electroplating tanks Chromium (total) - For Hard Chromium electroplating: 0.03 mg/dscm
- For Decorative Chromium electroplating: 0.01 mg/dscm 40 CFR 63.342 (c)(1)(ii)

40 CFR 63.342(d)(1)

1. Emission limits - Emissions from Electroplating Op erations shall not exceed the limitations specified in Table VIII.A. (9 VAC 5-80-110 and 40 CFR 63.342)

2. Emission Control - Chromium emissions from the electroplating tanks (PLATE-E1 through E3) shall be controlled by a Zenon packed tower scrubber (4620-C1). The scrubber shall be provided w ith adequate access for in spection and shall be in operation when the process is operating (9 VAC 5-80-110 and 40 CFR 63.342(a))

3. Operation and Maintenance Practices - The operation and maintenance of the Electroplating Operations shall be ca rried out as required by 40 CFR 63.342(f), including the Operation and Ma intenance Plan requirements. (9 VAC 5-80-110 and 40 CFR 63.342(f))

4. Requirements by Reference - Except where this permit is more restrictive than the applicable requirement, Electroplating Operatio ns are subject to the provisions of 40 CFR 63 Subpart N - National Emission Standards for Chromium Emissions from Hard and Decorative Chromium Electr oplating and Chromium Anodizing Tanks.

Note: All applicable requirements of 40 CFR 63 Subpart N may not be specifically listed in this permit. The permittee should refer to the applicable regulation for additional requirements not included in this permit. (9 VAC 5-80-110 and 40 CFR 63 Subpart N)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 58

B. Monitoring

1. The permittee shall visually inspect the packed scrubber (4620-C1) once per calendar quarter to ensure that there is proper drai nage, no chromic acid buildup on the packed beds, and no evidence of chemical attack on the structural integr ity of the device. The permittee shall note the results of the insp ections in a logbook to be maintained at the facility. (9 VAC 5-80-110 and 40 CFR 63.342(f))

2. The permittee shall visually inspect the back portion of the mist eliminator of the packed scrubber (4620-C1) once pe r calendar quarter to ensure that it is dry and that there is no breakthrough of chromic acid mist. The permittee shall note the results of the inspections in a logbook to be maintained at the facility. (9 VAC 5-80-110 and 40 CFR 63.342(f))

3. The permittee shall visually inspect the ductwork from each of the electroplating tanks (PLATE-E1 through E3) to the pack ed scrubber (4620-C1) once per calendar quarter to ensure that there are no leaks. The permittee shall note the results of the inspections in a logbook to be maintained at the facility. (9 VAC 5-80-110 and 40 CFR 63.342(f))

4. If greater than fifty percent (50%) of the scrubber water is drained for maintenance purposes, the permittee shall add fresh ma keup water to the top of the packedscrubber basin. The permittee shall keep maintenance records as required by 40 CFR 63.346(b)(2). (9 VAC 5-80-110 and 40 CFR 63.342(f))

5. The permittee shall monitor and record the velo city pressure at the inlet to the packed scrubber and pressure drop across the scrubbe r system once per day during operation. The values of inlet velocity pressure and pressure drop shall be noted in a logbook to be maintained at the facility and shall be current for the most recent 5-year period. The recorded values shall be compared to the values for inlet velocity pressure and pressure drop across the scrubber that indi cated compliance in initial compliance tests for the packed scrubber. The permittee sh all maintain a record of the initial compliance test at the facility for insp ection by DEQ for the life of the scrubber system. (9 VAC 5-80-110 and 40 CFR 63.343(c)(2))

6. The permittee shall monitor and record the operating times for each type of chromium electroplating processes (deco rative chromium or hard ch romium) performed in each of the units PLATE-E1 through E3. The permittee shall maintain the records as required by 40 CFR 63.346. (9 VAC 5-80-110 and 40 CFR 63.346)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 59 C. Recordkeeping

1. The permittee shall maintain records of a ll emission data and operating parameters necessary to demonstrate compliance with th is permit. The content and format of such records shall be arranged with the Di rector, Tidewater Regional Office. These records shall include, but are not limited to:

a. Quarterly inspections of the packed sc rubber (4620-C1) and duct work from the electroplating tanks (PLATE-E1 through E3 ) to the packed scrubber (4620-C1).

b. Daily records of ventilation velocity pressure and scrubber pressure drop.

c. All performance test results. Note: Record s of the initial compliance test shall be kept for the life of the scrubber system.

d. Maintenance records.

e. Malfunction and corrective actions records.

f. Records of operating times for each type of chromium electroplating processes.

g. Records to demonstrate that the maximum cumulative potential rectifier capacity of the facility is less than 60 million amp-hrs per year to qualify as a small hard chromium electroplating facility as defi ned in 40 CFR 63.341. This record shall be kept for the life of the chro mium electroplating facility.

These records shall be available on site for inspection by the DEQ and shall be current for the most recent five (5) years unless otherwise noted. (9 VAC 5-80-110 and 40 CFR 63.346)

D. Testing

1. If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method( s) in accordance with procedures in 40 CFR Subpart N and approved by the DEQ. (9 VAC 5-80-110 and 40 CFR 63.344)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 60 E. Reporting

1. The permittee shall prepare and submit semi -annual summary reports to document the ongoing compliance status of the electroplati ng facility. The report shall cover the time period including the previous six-mont h period (January through June and July through December, respectively) and shall include the following information at a minimum:

a. The company name and address of the affected source;

b. An identification of the operating parame ter(s) that is monitored for compliance determination, as required by 40 CFR 63.343(c);

c. The relevant emission limitation for th e affected source, and the operating parameter value, or range of values, th at correspond to compliance with this emission limitation as specified in the no tification of compliance status required by 40 CFR 63.347(e);

d. The beginning and ending date s of the reporting period;

e. A description of the type of proce ss performed in the affected source;

f. The total operating time of the affect ed source during the reporting period;

g. A summary of operating parameter values, including the total duration of excess emissions during the reporting period as indicated by those values, the total duration of excess emissions expressed as a percent of the total source operating time during that reporting period, and a brea kdown of the total duration of excess emissions during the reporting period into those that are due to process upsets, control equipment malfunctions, ot her known causes, and unknown causes;

h. A certification by a responsible official, as defined in 40 CFR 63.2, that the work practice standards in 40 CFR 63.342(f) were followed in accordance with the operation and maintenance plan for the source;

i. If the operation and maintenance plan required by 40 CFR 63.342(f)(3) was not followed, an explanation of the reason s for not following the provisions, an assessment of whether any excess emission and/or parameter monitoring exceedances are believed to have occurred, and a copy of the report(s) required by 40 CFR 63.342(f)(3)(iv) documenting that the operation and maintenance plan was not followed;

j. A description of any changes in monitoring, processes, or contro ls since the last reporting period;

k. The name, title, and signature of the res ponsible official who is certifying the accuracy of the report; andNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 61 l. The date of the report.

The permittee shall submit the report to the Director, Tidewater Regional Office no later than August 1 of each calendar year fo r the January through June time period and no later than February 1 of each calendar year for the July through December time period. (9 VAC 5-80-110 and 40 CFR 63.347(g)(3))



### IX. Painting Operations

A. Limitations

Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

Group P-X33, Group PX-15,
PSHIPSPRAY,and PSHIPBRUSH Units in Painting Operations, as

described in equipment list

(Section II) VOC, VOHAP 340 grams VOHAP per liter general use, air flask, inorganic zinc high-build, military exterior, nonskid, rubber camouflage, specialty interior, and undersea weapons systems coatings; 360 grams VOHAP per liter organic zinc coatings;

400 grams VOHAP per liter

anti-foulant coatings; 420 grams VOHAP per liter heat

resistant, high-gloss, and nuclear coatings; 490 grams

VOHAP per liter special marking coatings; 500 gramsVOHAP per liter hightemperature coatings; 530

grams VOHAP per liter antenna coatings; 550 grams VOHAP per liter navigational aids and repair and maintenance of thermoplastics coatings; 610 grams VOHAP per liter mist, sealant for thermal spray aluminum, and tack coat coatings; 650 grams VOHAP per liter weld-through preconditioning primer coatings; and 780 grams VOHAP per liter pretreatment wash primer coatings 40 CFR 63 Subpart IINational Emission Standards for Shipbuilding and Ship Repair (Surface Coating), Section 40 CFR 63.783(a)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 62
Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

4701-E10 through E13 combined Flame spray facility units, as described in equipment list (Section II) VOC Total VOC emissions from the flame spray facility shall not exceed 8 pounds per hour , 40 pounds per day, and 7 tons per year. 9 VAC 5-80-110 and Specific Condition 4 of

the 2/12/86 permit

205-C1a through c, 205- C2, 205-C3, and 206-C1 Units in Powder Coating Operation,

as described in equipment list

(Section II) PM, opacity Visible emissions from the exhausts of the natural gas and propane-fired equipment (205-

C1a through c, 205-C2, 205-

C3, and 206-C1) shall not exceed five percent (5%) opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix A). This condition applies at all times except during startup, shutdown, and malfunction. 9 VAC 5-50-80 and Condition 12 of the 2/14/01 NSR permit

1. Emission Limits- VOC and HAP emissions from Pa inting Operations shall not exceed the limitations specified in Table IX.A. (VAC 5-80-110 B)

2. Emission Limits- Unless otherwise specified, VOC and HAP emissions from marine coatings are subject to the provisions of 40 CFR 63 Subpart II - National Emission Standards for Shipbuilding and Ship Repair (Surface Coating). No owner or operator of any existing or new affected source sh all cause or allow th e application of any coating to a ship with an as-applied VOH AP content exceeding the applicable limits given in Table 2 of 40 CFR 63 Subpart II, as determined by the procedures described in 40 CFR 63.785 (a), (b), or (c)(1) thr ough (c)(4). For the compliance procedures described in Sec. 63.785 (c)(1) through (c)(3), VOC shall be used as a surrogate for VOHAP, and Method 24 of Appendix A to 40 CFR Part 60 shall be used as the definitive measure for determining compliance. For the compliance procedure described in 40 CFR 63.785(c)(4), an altern ative test method capable of measuring independent VOHAP shall be used to de termine compliance. The method must be submitted to and approved by DEQ. (9 VAC 5-80-110 B and 40 CFR 63.783(a))Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 63

3. Requirements by Reference - Except where this permit is more restrictive than the applicable requirement, the painting operations shall be operated in compliance with the requirements of 40 CFR 63 Subpart II. No te: All applicable requirements of 40 CFR 63, Subpart II may not be specifically listed in this permit. The permittee should refer to the applicable regulation for a dditional requirements not included in this permit. (9 VAC 5-80-110, and 40 CFR 63 Subpart II)

4. Emission Controls - VOC emissions from the powde r coating booth (250-PDR) shall be controlled by the use of powder coatings. Particulate emissions from the powder booth shall be controlled by total enclosure and capture of any powder coating overspray. A change to liquid coatings may require a permit. (9 VAC 5-80-110 and Condition 4 of 2/14/01 NSR permit)

5. Emission Controls - VOC emissions from the heat cleaning oven (206-C1) shall be controlled by a direct flame afterburner. The heat cleaning oven shall be operated according to manufacturer’s recommendation at a minimum. The heat cleaning oven shall be operated according to the following manufacturer's recommended procedures:

a. Step 1- The parts shall be batch-loaded into the oven;

b. Step 2- The afterburner is fired to a minimum temperature of 1,500 degrees Fahrenheit;

c. Step 3- The primary burner is fired;

d. Step 4- The oven doors are closed;

e. Step 5- The parts are heated until th e combustible materials decompose;

f. Step 6- The parts are removed and reused.

(9 VAC 5-80-1100 and Condition 5 of 2/14/01 NSR permit)

6. Emission Controls - VOC emissions from the part s washer (205-C1) shall be controlled by the use of non- volatile cleaning solutions. A change to solvent-based parts washing solutions may require a permit. (9 VAC 5-80-110 and Condition 6 of 2/14/01 NSR permit)

7. Throughput Limit - The throughput of powder coa tings in the Nordson powder booth (205-PDR) shall not exceed 9,461 tons per year, calculated monthly as the sum of each consecutive 12-month period. (9 VAC 5-80-110 and Condition 9 of 2/14/01 NSR permit)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 64 8. Throughput Limit The throughput of natural ga s for the parts-washer burners, preheat oven, and cure oven (Units 205-C1a through c, 205-C2, a nd 205-C3) combined shall not exceed 123.2 million cubic feet per year, calculated monthly as the sum of each consecutive 12-month period.

The throughput of liquid propane for the heat cleaning oven (Unit 206-C1) shall not exceed 57,442.6 gallons per year, calculated monthly as the sum of each consecutive 12-month period. (9 VAC 5-80-1100 and Condition 10 of 2/14/01 NSR permit)

9. Emission Limits - Emissions from the natural gas and propane-fired equipment (205- C1a through c, 205-C2, 205-C3, and 206-C1) co mbined shall not exceed the limits specified below:

Particulate Matter 0.5 tons/year

Nitrogen Oxides 6.6 tons/year (as NO 2 ) Carbon Monoxide 5.2 tons/year

These emissions are derived from the estimated overall emission contribution from operating limits. Exceedance of the operating limits shall be considered credible evidence of the exceedance of emission limits. Compliance with these emission limits may be determined as st ated in Condition number IX.A.8 (9 VAC 5-50-80 and Condition 11 of the 2/14/01 NSR permit)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 65

B. Monitoring and Recordkeeping

1. Compliance Determination - For each batch of marine co ating that is received by the facility, the permittee shall determine th e coating category, the applicable VOHAP limit as specified in 40 CFR 63.783(a), and ce rtify the as-supplied VOC content as specified in 40 CFR 63.785(a)(2) or (b)(1). The permittee may use a certification supplied by the manufacturer for the batch, although the permittee retains liability should subsequent testing reveal a viol ation. If the permittee performs the certification testing, only one of the cont ainers in which the batch coating was received is required to be tested. In lieu of testing each batch of coating, as applied, the permittee may determine complian ce with the VOHAP limits using any combination of the procedures described in 40 CFR 63.785 Paragraphs (c)(1), (c)(2), (c)(3), and (c)(4). The procedure used for each coating shall be determined and documented prior to application. The permitt ee shall log such data in a logbook to be maintained at the facility for inspection by DEQ for the most recent 5-year period. The results of any compliance demonstr ation conducted by the permittee or any regulatory agency using Method 24 shall ta ke precedence over the results using the procedures in 40 CFR 63.785 Paragraphs (c)(1) , (c)(2), or (c)(3). The results of any compliance demonstration conducted by the permittee or any regulatory agency using an approved test method to determine VOHA P content shall take precedence over the results using the procedures in 40 CFR 63.785 Paragraph (c)(4). (9 VAC 5-80-110 E, and 40 CFR 63.785(a) and (b))

2. Compliance Determination - The permittee shall ensure th at all handling and transfer of VOC-containing marine coating material s to and from containers, tanks, vats, drums, and piping systems is conducted in a manner that minimizes spills. The permittee shall inspect all containers, ta nks, vats, drums, and piping systems once monthly to ensure that they are free of cracks, holes, and other defects. All containers, vats, drums, and piping syst ems housing VOC-containing marine coating materials shall remain closed unless materi als are being added to or removed from them. Such procedures shall be documented in the facility's Shipbuilding and Ship Repair NESHAP Implementation Plan dated December 1996. (9 VAC 5-80-110 E, 40 CFR 63.783(b)(1) and (b )(2), and the Shipbuilding and Ship Repair NESHAP Implementation Plan submitted to EPA Region III dated December 1996)

3. Records of Marine Coatings - The permittee shall record the total volume of marine coatings applied at the facility to ships. Such records shall be compiled monthly and maintained at the facility for a minimum of 5-years. (9 VAC 5-80-110 F, and 40 CFR 63.788(b)(1))

4. Records of Marine Coatings - The permittee shall compile records of marine coatings on a monthly basis and maintain su ch records for a minimum of 5-years. Such records shall include, at a minimum:Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 66

a. All documentation supporting initial notification;

b. A copy of the facility's approved implementation plan;

c. The volume of each low-usage- exempt coating applied;

d. Identification of the coatings used, thei r appropriate coating categories, and the applicable VOC limit;

e. Certification of the as-supplied VOC content of each batch of coating;

f. A determination of whether containers m eet the standards as described in 40 CFR 63.783(b)(2);

g. The results of any Method 24 (as refere nced in 40 CFR 60, Appendix A) or approved VOC measurement test conducted on individual containers of coating, as applied; and

h. Any additional records as required by 40 CFR 63.788(b)(3) and (b)(4).

(9 VAC 5-80-110 F, and 40 CFR 63.788(b)(1) through (b)(4))

5. Monitoring Devices - The heat cleaning oven (206-C1) shall be equipped with a device to continuously measure and record the temperature inside the direct flame afterburner chamber. The monitoring device shall be installed, maintained, calibrated and operated in accordance with approved pr ocedures which shall include, as a minimum, the manufacturer's written requirements or recommendations. The monitoring device shall be pr ovided with adequate access for inspection and shall be in operation when the heat cleaning oven is operating. (9 VAC 5-80-110 and Condition 7 of 2/14/01 NSR permit)

6. Monitoring Device Observation - The device used to continuously measure temperature shall be observed by the pe rmittee once per operation to ensure good performance of the heat cleaning oven (206-C1 ) and its direct flame afterburner. The permittee shall continuously record temperature measurements from the heat cleaning oven while the oven is in operation. (9 VAC 5-80-110 and Condition 8 of 2/14/01 NSR permit)

7. Visible Emission Observations - The permittee shall observe each burner/oven stack of the powder coating oper ation (Units 205-C1a through c, 205-C2, 205-C3, and 206- C1) at least once per month when in opera tion for visible emissions for at least 6 minutes. If any visible emissions are not ed, corrective action shall be taken to eliminate the visible emissions. Results of observations and any corrective action shall be recorded in the operation log. Records of observati ons shall include the following: The name of the observer, Date and time of the observation,Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 67 An indication of presence or absence of visible emissions, The duration of any visible emission incident, and any corrective action to eliminate visible emissions.

(9 VAC 5-40-3370, 9 VAC 5-40-50 and 9 VAC 5-80-110 E)

8. Records for flame spray operation

- The permittee shall maintain daily records of paint and coating usage (in gallons) and VOC content (as applied) per coating for the flame spray operation (4701-E10 through E13) . The permittee shall calculate VOC emissions in pounds per hour and pounds pe r day once per calendar day based on the daily usage and VOC content (as applied) per coating. Daily is defined as the 24- hour period beginning at midnight of each ca lendar day and ending at 11:59 pm. Utilizing daily VOC emissions calculations , the permittee shall calculate annual VOC emissions in tons per year monthly as the sum of each consecutive 12-month period. Records of emissions calculations shall be ma intained at the facility for inspection by DEQ for the most recent 5-year period. (9 VAC 5-80-110 and Specific Condition 5 of 2/12/86 NSR permit)

9. Records for the powder coating operation - The permittee shall maintain records of emissions data and operating parameters for the powder coati ng operation (205-PDR) as necessary to demonstrate compliance with this permit. The content and format of such records shall be arranged with the Di rector, Tidewater Regional Office. These records shall include, but are not limited to:

a. Monthly and annual throughput (in tons) of powder coatings for each spray booth. Annual throughput shall be calculated mont hly as the sum of each consecutive 12- month period.

b. Monthly mass balance records of the amount of powder coatings used and the amount of powder coating overspray collected and recycled in pounds. In addition, powder coating purch ase records shall be mainta ined for the most recent 12-month period indicating at minimum th e type and amount in pounds of powder coating purchased.

c. Annual throughput of natural gas in cubic feet per year for units 205-C1a through c, 205-C2, and 205-C3, and throughput of propane in gallons per year for unit 206-C1, calculated monthly as the su m of consecutive 12-month period.

d. Records of the afterburner temperature when the heat cleaning ovens (Unit 206- C1) is in operation (circle or strip chart).

e. Records of all visibl e emission observations.

These records shall be available for inspection by DEQ and shall be current for the most recent 5-year period. (9 VAC 5-80-1100 and Condition 13 of 2/14/01 NSR permit)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 68 C. Testing

1. For the compliance procedures descri bed in 40 CFR 63.785(c)(1) through (c)(3), Method 24 of 40 CFR Part 60, Appendix A is the definitive method for determining the VOC content of coatings, as supplied or as applied. Compliance with each limitation in Table IX.A shall be ba sed on compliance with the monitoring, recordkeeping, and reporting provisions of this section. (9 VAC 5-80-110 B, and 40 CFR 63.786(a))

2. If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approved by the DEQ. (9 VAC 5-80-110)

D. Reporting

1. Before the 60th day following comple tion of each 6-month period after the compliance date specified in 40 CFR 63.784, the permittee shall submit a VOC report on marine coatings to the Director, Ti dewater Regional Office for each of the previous 6 months. The report shall include all of the information that must be retained pursuant to 40 CFR 63.788(b)(2) through (b)(3), ex cept for that information specified in 40 CFR 63.788(b)(2 )(i) through (ii), (b)(2)(v), (b )(3)(i)(A), (b)(3)(ii)(A), and (b)(3)(iii)(A). If a violation is de tected, the permittee shall also report the information specified in 40 CFR 63.788(b )(4) for the reporting period during which the violation(s) occurred. To the extent possible, the report shall be organized according to the compliance procedure(s) followed each month by the permittee. (9 VAC 5-80-110 F, and 40 CFR 63.788(c))Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 69



### X. Specialty Shops Requirements

A. Limitations

Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

64-E1 Electrical Shop drill press/sander (not used for wood) PM E=4.10P 0.67 where P is the process weight rate in tons/hour and E is the PM

emission rate in lbs/hr 9 VAC 5-40-260

64-E2 Electrical Shop saw PM E=4.10P 0.67 where P is the process weight rate in tons/hour and E is the PM

emission rate in lbs/hr 9 VAC 5-40-260

64-E9 Grinding metal PM E=4.10P 0.67 where P is the process weight rate in tons/hour and E is the PM

emission rate in lbs/hr 9 VAC 5-40-260

60-E2 Grinding operations PM E=4.10P 0.67 where P is the process weight rate in tons/hour and E is the PM

emission rate in lbs/hr 9 VAC 5-40-260

114-E1 Saw metals PM E=4.10P 0.67 where P is the process weight rate in tons/hour and E is the PM

emission rate in lbs/hr 9 VAC 5-40-260

4896-E1 Melamine Operations (2 Milling Machines, Band Saw, and Lathe) PM E=4.10P 0.67 where P is the process weight rate in tons/hour and E is the PM

emission rate in lbs/hr 9 VAC 5-40-260

64-E1, 64-E2, 64-E9, 60-E2, 114-E1, and 4896- E1 As described above Opacity Visible emissions shall not exceed 20 percent opacity

except for one 6-minute period in any one hour of not more than 60 percent opacity. 9 VAC 5-40-80

64-E3 Bayco Model BB 288 burn-out oven using propane, 1979 PM PM emissions from the burn-out oven shall not exceed 0.16 lbs/hr and 0.71 tons/yr Condition 2 of 10/18/1979 NSR PermitNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 70
Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

64-E3 As described above Opacity Visible emissions shall not exceed 20 percent opacity

except for one 6-minute period in any one hour of not more than 30 percent opacity. This condition applies at all times except during startup, shutdown, and malfunction. 9 VAC 5-50-80 and 10/18/1979 NSR Permit

FAC-PW Facility-wide parts washer operations VOC Minimum reduction of 85% by weight of VOCs by use

of appropriate control technology guidelines (CTGs) as outlined in 9

VAC 5-40-3290 C 9 VAC 5-40-3280.C

1. Emission Limits - Particulate emissions and VOC em issions from the specialty shop units shall not exceed the limits specified in Table X.A. (9 VAC 5-80-110 and 10/18/1979 NSR Permit)

2. Emission Control - Emissions from the burn-out oven (Unit Ref. No. 64-E3) shall be controlled by an afterburner. The afterbur ner shall be provided with adequate access for inspection. (9 VAC 5-80-110 and 10/18/1979 NSR Permit)

3. Fuel - The approved fuel for the burn-out oven is propane. A change in the fuel may require a permit to modify and operate. (9 VAC 5-80-110 and Condition 6 of 10/18/1979 NSR permit)

4. Emission Control - Cold cleaning parts washers (Unit Ref. No. FAC-PW) shall be equipped with a control method that will re move, destroy, or prevent the discharge into the atmosphere of at least 85% by weight of volatile organic compound emissions. Achievement of the VOC em ission standard shall be achieved by complying with the applicable control re quirements and operating requirements in 9 VAC 5-40-3290 C.1 and C.2, respectively. (9 VAC 5-40-3290 C and 9 VAC 5-80-110 B)

5. Emission Control - Disposal of waste solvent from the parts washer operations (Unit Ref. No. FAC-PW) should be achieved by recl amation (either by outside services or in-house) or by incineration. Di sposal records shall be main tained at the facility for the most recent 5-year period. (9 VAC 5-40-3290.D)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 71 B. Monitoring

1. The permittee shall monitor each of the units in Specialty Shop operations except for the parts-washers (Unit Ref. No. FAC-PW) at least once per month when in operation for visible emissions for at least 6 minutes. If visible emissions are noted, corrective action shall be taken to eliminate the visibl e emissions. If visible emissions continue after corrective actions, a visible emissi ons evaluation (VEE) shall be immediately conducted on the stack for at least six mi nutes in accordance with Method 9 (40 CFR 60, Appendix A). If the VEE opacity average for the stack exceeds ten percent (10%), the VEE shall continue for one hour from initiation to determine compliance with the opacity limit. Results of observati ons and/or VEEs shall be recorded in the operation log. Records of observati ons shall include the following: The name of the observer, Date and time of the observation, An indication of presence or absence of visible emissions, The duration of any visible emission incident, and any corrective action to eliminate visible emissions. If a VEE is conducted, r ecords shall be in accordance with Method 9 (40 CFR 60, Appendix A). (9 VAC 5-80-110 E)

2. The permittee shall inspect each parts wash er unit quarterly to ensure compliance with the control requirements of 9 VAC 5- 40-3290 C. If such inspections indicate any condition of non-compliance, appropriate action shall be taken to correct the problem. (9 VAC 5-40-3290 C and 9 VAC 5-80-110 E)

3. At all times the disposal of volatile organic compounds shall be accomplished by taking measures, to the extent practicable , consistent with air pollution control practices for minimizing emissions. Vo latile organic compounds shall not be intentionally spilled, discarded in sewers which are not connected to a treatment plant, or stored in open cont ainers or handled in any othe r manner that would result in evaporation beyond that consistent with ai r pollution control practices for minimizing emissions. (9 VAC 5-40-20 F and 9 VAC 5-80-110 E)

C. Recordkeeping

1. The permittee shall maintain records of a ll emission data and operating parameters necessary to demonstrate compliance with th is permit. The content and format of such records shall be arranged with the Di rector, Tidewater Regional Office. These records shall include, but are not limited to:

a. Records of visible emission observations and visible emission evaluations (VEE), if performed,Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 72 b. Records of waste solvent disposal, and

c. Records of parts-washer insp ections and corrective actions.

These records shall be available on site for inspection by the DEQ and shall be current for the most recent five (5) years.
(9 VAC 5-80-110)

D. Testing

1. If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approved by the DEQ. (9 VAC 5-80-110)



### XI. Miscellaneous Activities

A. Limitations

Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

250-E2 Arc gouger PM E=4.10 P 0.67 where P is the process weight rate in tons/hour and E is the PM emission rate in lbs/hr 9 VAC 5-40-260

250-E2 Arc gouger Opacity Visible emissions from the currently permitted arc gouger dust collector shall not exceed 5 percent (5%) opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix A). This condition applies at all times except during startup, shutdown, and malfunction. Condition 5 of 9/02/94 NSR Permit

205-B1 through

B2 Powder Coating Facility steel shot blast units (2) Opacity Visible emissions shall not exceed five percent (5%) opacity as determined by EPA Method 9 (reference 40 CFR 60, Appendix A). This condition applies at all times except during startup, shutdown, and malfunction. Condition 12 of 2/14/01 NSR PermitNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 73
Unit Name Name/Description of Unit Pollutants Description of Applicable Requirement/ Emission Limit/Standard/Work Practice Citation

50-E1, 4730-NB, 4730-SB, 201-E1,
Port-E1 through

E31, 4701-E1, 1768-E1, 250-E1, 263-E1, 4677-E1, 501-E5, 75-E5, 74-E1,
5-E2 See Section II Opacity Visible emissions from existing (pre-March 17,1972) emission units which vent to

the atmosphere shall not exceed 20 percent opacity

except for one 6-minute period in any one hour of not more than 60 percent opacity.

Visible emissions from new (on or after March 17,1972) emission units without specific permitted opacity

limit which vent to the atmosphere shall not exceed 20 percent opacity except for

one 6-minute period in any one hour of not more than 30 percent opacity. 9 VAC 5-40-80

9 VAC 5-50-80

50-E1, 4730-NB, 4730-SB, 201-E1,
Port-E1 through

E31, 4701-E1, 1768-E1, 250-E1, 263-E1, 4677-E1, 501-E5, 75-E5, 74-E1,
5-E2 See Section II PM E=4.10 P 0.67 where P is the process weight rate in tons/hour and E is the PM emission rate in lbs/hr 9 VAC 5-40-260

1. Emission Control - Particulate emissions from th e arc-gouging process (Unit Ref. No. 250-E2) shall be controlled by a dust co llector. The dust collector shall be provided with adequate access for inspection and shall be in operation when the arcgouger is operating. (9 VAC 5-80-10 H and Condition 3 of 9/2/94 NSR permit)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 74

2. Throughput Limit - The arc gouger (Unit Ref. No. 250-E2) shall process no more than 88,000 linear feet of stainless steel pe r year, calculated mont hly as the sum of each consecutive 12-month period. (9 VAC 5-170-160 and Condition 4 of the 9/2/94 NSR permit)

3. Emission Control - Particulate emissions from the Powder Coating Operation steel shot blast units (Units 205-B1 and B2) shall be controlled by cartridge filters. The cartridge filters shall be provided with ade quate access for inspection and shall be in operation when the blasting process is operating. (9 VAC 5-80-110 and Condition 3 of the 2/14/01 NSR permit)

4. Requirements by Reference - Except where this permit is more restrictive than the applicable requirement, Site Remediation Activ ities at the facility shall be subject to the provisions of 40 CFR 63 Subpart GGGGG - National Emission Standards for Hazardous Air Pollutants: Site Remediation.

Note: All applicable requirements of 40 CFR 63 Subpart GGGGG may not be specifically listed in this permit. The permittee should refer to the applicable regulation for additional requirements not included in this permit. (9 VAC 5-80-110 and 40 CFR 63 Subpart GGGGG)

B. Monitoring

1. Monitoring Device - The dust collector (PDC ID No. 250-C2) of the arc-gouging process (Unit Ref. No. 250-E2) shall be equipped with a device to continuously measure the differential pressure drop acro ss the fabric filter. The device shall be installed in an accessible location and shall be maintained by the permittee such that it is in proper working order at all times. (9 VAC 5-80-110 and Condition 3 of 9/02/94 NSR permit)

2. Monitoring Device Observations - Differential pressure drop of the arc gouger dust collector (250-C2) shall be observed once per week when in operation to ensure proper operation of the dust collector. The observations shall be noted in a log book with the following information: The name of the observer, Date and time of the observation, Pressure drop, and Any corrective action. (9 VAC 5-80-110 E)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 75

3. Visible Emission Evaluations - The permittee shall perform a visible emission evaluation on the arc gouger (250-E2) once pe r month when the unit is in operation during daylight hours of operati on for at least eighteen mi nutes in accordance with EPA Method 9 (reference 40 CFR 60, Appendi x A). If any visible emissions are noted, corrective action shall be taken to el iminate the visible emissions. Records of the visible emission evaluations shall be in accordance with Method 9 (40 CFR 60, Appendix A). (9 VAC 5-80-110 E)

4. Visible Emission Observations- The permittee shall observe the stack/vent of each the powder coating steel shots blast units (205-B1 and B2) at least once per week (Monday-Sunday) when in operation for visibl e emissions for at least 6 minutes. If any visible emissions are noted, corrective action shall be taken to eliminate the visible emissions. Results of observations and any corrective action shall be recorded in the operation log. (9 VAC 5-80-110 E)

5. Visible Emission Observations- The permittee shall observe the stack of each unit in Miscellaneous Activities which vent to the atmosphere other than the arc gouger (250-E2) and the powder coating steel shots blast units (205-B1 and B2) at least once per month when in operation for visible emi ssions for at least 6 minutes. If visible emissions are noted, corrective action sha ll be taken to eliminate the visible emissions. If visible emissions continue after corrective actions, a visible emissions evaluation (VEE) shall be immediately conduc ted on the stack for at least six minutes in accordance with Method 9 (40 CFR 60, Appe ndix A). If the VEE opacity average for the stack exceeds ten percent (10%), the VEE shall continue for one hour from initiation to determine compliance with th e opacity limit. Results of observations and/or VEEs shall be recorded in the ope ration log. Records of observations shall include the following: The name of the observer, Date and time of the observation, An indication of presence or absence of visible emissions, The duration of any visible emission incident, and any corrective action to eliminate visible emissions. If a VEE is conducted, r ecords shall be in accordance with Method 9 (40 CFR 60, Appendix A). (9 VAC 5-80-110 E)

6. Monitoring of Site Remediation Activities - The permittee shall monitor the total quantity of the HAPs listed in table 1 of 40 CFR 63 Subpa rt GGGGG that is contained in the remediation material ex cavated, extracted, pumped, or otherwise removed during all of the site remediations condu cted at the facility to show that it is less than 1 megagram annually and the facility is exempt from the requirements of 40 CFR 63 Subpart GGGGG. (9 VAC 5-80-110 and 40 CFR 63.7881(c)(1))Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 76 C. Recordkeeping

1. The permittee shall maintain records of a ll emission data and operating parameters necessary to demonstrate compliance with th is permit. The content and format of such records shall be arranged with the Di rector, Tidewater Regional Office. These records shall include, but are not limited to:

a. The annual throughput of stainless steel ca tapult plates for th e arc gouger in linear feet, calculated monthly as the sum of each consecutive 12-month period.

b. Records of differential pressure drops fo r the arc gouger dust collector (250-C2).

c. Records of visible emissi on evaluations of the arc gouger (250-E2) using EPA Method 9 (reference 40 CFR 60, Appendi x A) and any corrective action.

d. Records of visible emissions observati ons, any corrective action, and visible emission evaluations using EPA Method 9 (reference 40 CFR 60, Appendix A), if performed, for Miscellaneous Activities uni ts other than the arc gouger (250-E2).

e. Records of written documentation to suppor t the determination that the total HAP quantity in the remediation materials is le ss than 1 megagram per year from all remediation activities at your facil ity as required by 40 CFR 63.7881(c)(2) to qualify for exemption from the requirements of 40 CFR 63 Subpart GGGGG. The documentation must include a descri ption of your methodology and data used for determining the total HAP content of the remediation material.

These records shall be available on site for inspection by the DEQ and shall be current for the most recent five (5) years.
(9 VAC 5-80-110, Condition 7 of 9/02/ 94 NSR Permit, and 40 CFR 63.7881(c))

D. Testing

1. If testing is conducted in addition to the monitoring specified in this permit, the permittee shall use the appropriate method(s) in accordance with procedures approved by the DEQ. (9 VAC 5-80-110)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 77



### XII. Insignificant Emission Units The following emission units at the facility are identified in the application as insignificant emission units under 9 VAC 5-80-720:

Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C)

103-E1 Shop- Perkins Diesel Generator 9 VAC 5-80-720 C NA 40 Hp

160-E1 Tool Room & OfficePerkins Diesel Generator 9 VAC 5-80-720 C NA 40 Hp

1744-E3 Utility Substation Emergency Generator 9 VAC 5-80-720 C NA 80.4 Hp

1744-E4 Natural Gas-Fired Boiler 9 VAC 5-80-720 C NA 2.343 MMBTU/hr

1744-E5 Natural Gas-Fired Boiler 9 VAC 5-80-720 C NA 2.343 MMBTU/hr

1796-E1 Natural Gas-Fired Boiler, #42806, 2006 9 VAC 5-80-720 C NA 2.0 MMBTU/hr

23-E1 Hull Outfitting & Electrical Shops - Perkins Diesel Generator 9 VAC 5-80-720 C NA 40 Hp

2-E1 Consolidated Storage - Perkins Diesel Emergency Generator 9 VAC 5-80-720 C NA 40 Hp

4632-E1 Radcon Control Firehouse - Caterpillar Diesel Emergency Generator 9 VAC 5-80-720 C NA 324 Hp

4677-E2 MOF, South - Cummins Diesel Emergency Generator 9 VAC 5-80-720 C NA 80 Hp

4677-E3 MOF, North - Cummins Diesel Emergency Generator 9 VAC 5-80-720 C NA 67 Hp

4677-E4 MOF, East - Detroit Diesel Emergency Generator 9 VAC 5-80-720 C NA 47 Hp

4677-E5 Natural Gas Fired Boiler 9 VAC 5-80-720 C NA 2.0 MMBTU/hr

4677-E6 Natural Gas Fired Boiler 9 VAC 5-80-720 C NA 2.0 MMBTU/hr

520-E1 Office - Perkins Diesel Emergency Generator 9 VAC 5-80-720 C NA 67 Hp

521-E1 Computer & Materials Support - Cummins Diesel Emergency Generator 9 VAC 5-80-720 C NA 603 Hp

86-E1 Perkins Diesel Emergency Generator 9 VAC 5-80-720 C NA 235 HpNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 78
Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C) DD10/11-E1 Cummins Diesel Generator 9 VAC 5-80-720 C NA 469 Hp

DD3-E1 Cummins Diesel Generator 9 VAC 5-80-720 C NA 335 Hp
DD3-E2 Detroit Diesel Generator 9 VAC 5-80-720 C NA 335 Hp
DD4-E1 Caterpillar Diesel Generator 9 VAC 5-80-720 C NA 208 Hp
DD4-E2 Caterpillar Diesel Generator 9 VAC 5-80-720 C NA 208 Hp
GEN-E10 Cummins Diesel Generator 9 VAC 5-80-720 C NA 282 Hp

GEN-E11 Fire Dept. #1-port - Caterpillar Diesel Emergency Generator 9 VAC 5-80-720 C NA 268 Hp

GEN-E12 Fire Dept. #2-port - Caterpillar Diesel Emergency Generator 9 VAC 5-80-720 C NA 268 Hp

GEN-E13 Detroit Diesel Generator 9 VAC 5-80-720 C NA 188 Hp
GEN-E14 Detroit Diesel Generator 9 VAC 5-80-720 C NA 168 Hp
GEN-E15 Diesel-fired Generator 9 VAC 5-80-720 C NA 168 Hp
GEN-E16 Detroit Diesel Generator 9 VAC 5-80-720 C NA 80 Hp

GEN-E17 Communications Tower - Detroit Diesel Generator 9 VAC 5-80-720 C NA 282 Hp

GEN-E18 Portable - Detroit Diesel Generator 9 VAC 5-80-720 C NA 282 Hp

GEN-E19 Scrap Yard Fuel Storage Facility - Detroit Diesel Generator 9 VAC 5-80-720 C NA 46.9 Hp

GEN-E20 Ring Module Shop - Generac Diesel Generator Set 9 VAC 5-80-720 C NA 40.2 Hp

GEN-E22 Emergency Diesel Generator 9 VAC 5-80-720 C NA 67.1 Hp

GEN-E23 Emergency Diesel Generator 9 VAC 5-80-720 C NA 67.1 Hp

GEN-E24 Emergency Diesel Generator 9 VAC 5-80-720 C NA 11 Hp

GEN-E25 Emergency Diesel Generator 9 VAC 5-80-720 C NA 11 Hp

GEN-E26 Emergency Diesel Generator 9 VAC 5-80-720 C NA 67.1 Hp

GEN-E27 Emergency Diesel Generator 9 VAC 5-80-720 C NA 40.2 HpNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 79
Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C)

GEN-E28 Emergency Diesel Generator 9 VAC 5-80-720 C NA 40.2 Hp

GEN-E29 Emergency Diesel Generator 9 VAC 5-80-720 C NA 40 Hp

GEN-E30 Emergency Diesel Generator 9 VAC 5-80-720 C NA 40 Hp

GEN-E31 Emergency Diesel Generator 9 VAC 5-80-720 C NA 40 Hp

GEN-E32 Emergency Diesel Generator 9 VAC 5-80-720 C NA 67 Hp

GEN-E33 Emergency Diesel Generator 9 VAC 5-80-720 C NA 93.9 Hp

GEN-E5 Detroit Diesel Generator 9 VAC 5-80-720 C NA 603.5 Hp

GEN-E6 Cummins/Onan Diesel Generator Set 9 VAC 5-80-720 C NA 402 Hp

GEN-E7 Detroit Diesel Generator 9 VAC 5-80-720 C NA 335 Hp
GEN-E8 Detroit Diesel Generator 9 VAC 5-80-720 C NA 335 Hp
GEN-E9 Cummins Diesel Generator 9 VAC 5-80-720 C NA 308 Hp

PIER2-E1 Cummins Diesel Emergency Generator 9 VAC 5-80-720 C NA 469 Hp

GEN-E34 Detroit Diesel Generator 9 VAC 5-80-720 C NA 47 Hp

GENP-E1 Portable Generators Rated at equal to or greater than 14 kW 9 VAC 5-80-720 C NA <12 Hp

PUMP-E1 Cummins 6” Portable Emergency Diesel Pump 9 VAC 5-80-720 C NA 95.2 Hp

PUMP-E2 Cummins 6” Portable Emergency Diesel Pump 9 VAC 5-80-720 C NA 95.2 Hp

550-E15 Heat Treating Furnace 3, #39386 9 VAC 5-80-720 C NA 1.3 MMBTU/hr

550-E6 Core Sand Dryer, #5646 9 VAC 5-80-720 C NA 2.5 MMBTU/hr
274-E2 Binks Dryer, Propane 9 VAC 5-80-720 C NA 0.9 MMBTU/hr
274-E3 Binks Dryer, Propane 9 VAC 5-80-720 C NA 2.4 MMBTU/hr

274-E4 Buffalo Forge-Space Heating Flat Prep. Inspection, propane 9 VAC 5-80-720 C NA 1.88 MMBTU/hr

274-E5 Buffalo Forge-Space Heating Flat Prep. Inspection, propane 9 VAC 5-80-720 C NA 0.56 MMBTU/hrNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 80
Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C)

274-E6 Buffalo Forge-Space Heating Flat Prep. Inspection, propane 9 VAC 5-80-720 C NA 0.56 MMBTU/hr

274-E7 Buffalo Forge-Space Heating Flat Prep. Inspection, propane 9 VAC 5-80-720 C NA 1.88 MMBTU/hr

274-E8 Buffalo Forge-Space Heating Flat Prep. Inspection, propane 9 VAC 5-80-720 C NA 0.56 MMBTU/hr

274-E9 Wing Heat-Space Heating Flat Prep. Inspection,
propane 9 VAC 5-80-720 C NA 0.4 MMBTU/hr

274-E10 Wing Heat-Space Heating Flat Prep. Inspection,
propane 9 VAC 5-80-720 C NA 0.4 MMBTU/hr

274-E11 Wing Heat-Space Heating Flat Prep. Inspection,
propane 9 VAC 5-80-720 C NA 0.4 MMBTU/hr

275-E1 Thermal Dryer, propane 9 VAC 5-80-720 C NA 3.2 MMBTU/hr

275-E2 Buffalo Forge - Shape Prep,
propane 9 VAC 5-80-720 C NA 1.88 MMBTU/hr

275-E3 Buffalo Forge - Shape Prep,
propane 9 VAC 5-80-720 C NA 1.88 MMBTU/hr

276-E5 Oven, propane 9 VAC 5-80-720 C NA 2.58 MMBTU/hr

1746-E2 Electrolux Paint Dryer - Plate Preparation, propane 9 VAC 5-80-720 C NA 8.33 MMBTU/hr

1746-E3 Electrolux Paint Dryer - Plate Preparation, propane 9 VAC 5-80-720 C NA 8.33 MMBTU/hr

4582-E7 Lead Finishing Radiant Heater 9 VAC 5-80-720 C NA 0.023 MMBTU/hr

4582-E8 Lead Finishing Radiant Heater 9 VAC 5-80-720 C NA 0.023 MMBTU/hr

4582-E9 Lead Finishing Radiant Heater 9 VAC 5-80-720 C NA 0.023 MMBTU/hr

4582-E10 Lead Finishing Radiant Heater 9 VAC 5-80-720 C NA 0.023 MMBTU/hr

4582-E11 Lead Finishing Radiant Heater 9 VAC 5-80-720 C NA 0.023 MMBTU/hr

4619-E1 Sludge dryer - electric 9 VAC 5-80-720 C NA NA

17-E2 Super heater - Ship Repair Machine Shop 9 VAC 5-80-720 C NA 0.6 MMBTU/hrNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 81
Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C)

60-E4 Curing Oven - Main Machine Shop (w/ filter) 9 VAC 5-80-720 C NA 0.175 MMBTU/hr

205-E1 Oven - Ship Shed No. 3 9 VAC 5-80-720 C NA 0.214 MMBTU/hr

4740-E1 Oven 9 VAC 5-80-720 C NA 0.183 MMBTU/hr
4702-EF2 Dryer 9 VAC 5-80-720 C NA 1.1 MMBTU/hr

4681-E1 Bake Oven at Phosphate Line 9 VAC 5-80-720 C NA 4.2 MMBTU/hr

PLATE-E4 Chromium strip tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E5 Electrocleaner tank - Cd 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E6 Electrocleaner tank - Cu/Ni 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E7 Electrocleaner tank - Cr/Ni 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E8 Electrocleaner tank - Cr 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E9 Electrocleaner tank - Cr/Ni 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E10 Chromic acid tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E11 Cadmium plating tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E12 Barrel cadmium plating 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E13 Zinc plating tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E14 Barrel zinc plating 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E15 Cyanide copper tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NANorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 82
Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C)

PLATE-E16 Nickel plating tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E17 Nickel strip tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E18 Dull nickel plating tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E19 Lead plating tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E20 Silver strike tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E21 Silver plating tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

PLATE-E22 Acid copper plating tank 9 VAC 5-80-720 B Metallic oxides and non-HAP inorganic compounds NA

29-PT Pickling Tank, 6,400 gal 9 VAC 5-80-720 B H 2 SO 4 NA

161-PT Four Pickling Tanks, each 3,240 gal 9 VAC 5-80-720 B H 2 SO 4 NA

SY-E1 Natural gas-fired boiler, Rite 9 VAC 5-80-720 C NA 0.48 MMBTU/hr

4768-E1 Natural gas-fired boiler, Burnham 9 VAC 5-80-720 C NA 2.8 MMBTU/hr

4768-E2 Natural gas-fired boiler, Burnham 9 VAC 5-80-720 C NA 2.8 MMBTU/hr

17-E1 Propane-fired test boiler, Singer Vapor 9 VAC 5-80-720 C NA 2.73 MMBTU/hr

521-E1 Natural gas-fired boiler, Aerco 9 VAC 5-80-720 C NA 2.0 MMBTU/hr

521-E2 Natural gas-fired boiler, Aerco 9 VAC 5-80-720 C NA 2.0 MMBTU/hr

521-E3 Natural gas-fired boiler, Aerco 9 VAC 5-80-720 C NA 2.0 MMBTU/hr

521-E4 Natural gas-fired boiler, Aerco 9 VAC 5-80-720 C NA 2.0 MMBTU/hr

521-E5 Natural gas-fired boiler, Aerco 9 VAC 5-80-720 C NA 2.0 MMBTU/hrNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 83
Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C)

521-E6 Natural gas-fired boiler, Aerco 9 VAC 5-80-720 C NA 2.0 MMBTU/hr

521-E7 Natural gas-fired boiler, Aerco 9 VAC 5-80-720 C NA 2.0 MMBTU/hr

5664 / 4677- SHT Special Hull Treatment 9 VAC 5-80-720 B VOC NA

276-CNC CNC Cutting Machine 9 VAC 5-80-720 B PM NA

1865-CMAF Carrier Modular Assembly Facility – Platen #21 9 VAC 5-80-720 B PM NA

1865- CMAFB1- B10 10 Natural gas-fired space heaters at CMAF 9 VAC 5-80-720 C NA 2.4 MMBTU/hr each

907-E1 LA-4123 PVC Seam Adhesive Operation 9 VAC 5-80-720 B MEK, VOC NA

518-E1 Nitrogen/Oxygen Cylinder Purge & Clean Operation 9 VAC 5-80-720 B TCE, VOC NA

1833-E1 Saw for Calcium Silicate Insulation, 1.5 Hp 9 VAC 5-80-720 B Vents Inside Building NA

4698-E1 Portable ALC Sandy Jet Pressure Blaster 9 VAC 5-80-720 B PM NA

1872-CMOF Carrier Modular Outfitting Facility 9 VAC 5-80-720 B PM NA

5-E1 Metal grinder, 0.1 Lb/Hr 9 VAC 5-80-720 B PM NA
A209 Diesel Tank, 1,000 gallons 9 VAC 5-80-720 B VOC NA
A210 Diesel Tank, 1,000 gallons 9 VAC 5-80-720 B VOC NA
A211 Diesel Tank, 180 gallons 9 VAC 5-80-720 B VOC NA
A212 Diesel Tank, 270 gallons 9 VAC 5-80-720 B VOC NA
A218 Diesel Tank, 3,000 gallons 9 VAC 5-80-720 B VOC NA
A219 Diesel Tank, 1,000 gallons 9 VAC 5-80-720 B VOC NA
A220 Diesel Tank, 2,200 gallons 9 VAC 5-80-720 B VOC NA
A221 Diesel Tank, 1,000 gallons 9 VAC 5-80-720 B VOC NA
A222 Diesel Tank, 1,000 gallons 9 VAC 5-80-720 B VOC NA
A223 Diesel Tank, 5,000 gallons 9 VAC 5-80-720 B VOC NA
A224 Diesel Tank, 1,500 gallons 9 VAC 5-80-720 B VOC NA
A225 Diesel Tank, 6,000 gallons 9 VAC 5-80-720 B VOC NA
A226 Diesel Tank, 6,000 gallons 9 VAC 5-80-720 B VOC NA
A227a Diesel Tank, 12,000 gallons 9 VAC 5-80-720 B VOC NANorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 84
Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C) A227b Diesel Tank, 12,000 gallons 9 VAC 5-80-720 B VOC NA

A228 Diesel Tank, 300,000 gallons 9 VAC 5-80-720 B VOC NA

A301 Recycled Oil Tank, 19,827 gallons 9 VAC 5-80-720 B VOC NA

A302 Recycled Oil Tank, 19,827 gallons 9 VAC 5-80-720 B VOC NA

A401 Oily Waste Tank, 60,000 gallons 9 VAC 5-80-720 B VOC NA

A402 Oily Waste Tank, 60,000 gallons 9 VAC 5-80-720 B VOC NA

A403 Oily Waste Tank, 8,310 gallons 9 VAC 5-80-720 B VOC NA

A405 Oily Wastewater Tank, 25,000 gallons 9 VAC 5-80-720 B VOC NA

A407 Oily Wastewater Tank, 1,000 gallons 9 VAC 5-80-720 B VOC NA

A408 Oily Wastewater Tank, 1,000 gallons 9 VAC 5-80-720 B VOC NA

A409 Oily Wastewater Tank, 1,000 gallons 9 VAC 5-80-720 B VOC NA

A410 Waste Oil Tank 9 VAC 5-80-720 C NA 275 gallons

A411 Waste Oil Tank 9 VAC 5-80-720 C NA 225 gallons

A414 Oily Wastewater Tank, 6,000 gallons 9 VAC 5-80-720 B VOC NA

A415 Oily Wastewater Tank, 2,000 gallons 9 VAC 5-80-720 B VOC NA

A508 Diesel Tank, 530 gallons 9 VAC 5-80-720 B VOC NA
A509 Diesel Tank, 530 gallons 9 VAC 5-80-720 B VOC NA
A510 Diesel Tank, 530 gallons 9 VAC 5-80-720 B VOC NA
A511 Diesel Tank, 270 gallons 9 VAC 5-80-720 B VOC NA
A512 Diesel Tank, 270 gallons 9 VAC 5-80-720 B VOC NA
A513 Diesel Tank, 270 gallons 9 VAC 5-80-720 B VOC NA
A514 Jet-Fuel Tank, 2,000 gallons 9 VAC 5-80-720 B VOC NA

A601-A635 Oily Waste Tank, 910 gallons 9 VAC 5-80-720 B VOC NA

V706 Diesel Tank, 500 gallons 9 VAC 5-80-720 B VOC NA

V707 Oily Waste Tank, 10,000 gallons 9 VAC 5-80-720 B VOC NA

U232 Diesel Tank, 1,000 gallons 9 VAC 5-80-720 B VOC NANorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 85
Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C)

U305 Gasoline Tank, 6,000 gallons 9 VAC 5-80-720 B VOC NA

U503 No. 6 Oil Tank, 500,000 gallons 9 VAC 5-80-720 B VOC NA

U504 No. 6 Oil Tank, 171,000 gallons 9 VAC 5-80-720 B VOC NA

U505 No. 6 Oil Tank, 171,000 gallons 9 VAC 5-80-720 B VOC NA

U508 No. 6 Oil Tank, 10,000 gallons 9 VAC 5-80-720 B VOC NA

U511 Oily Water Tank, 48,000 gallons 9 VAC 5-80-720 B VOC NA

U512 Oily Water Tank, 20,000 gallons 9 VAC 5-80-720 B VOC NA

U513 Oily Water Tank, 20,000 gallons 9 VAC 5-80-720 B VOC NA

U514 Oily Water Tank, 30,000 gallons 9 VAC 5-80-720 B VOC NA

U517 Oily Water Tank 9 VAC 5-80-720 C NA 550 gallons

U518 Oily Water Tank, 3,918 gallons 9 VAC 5-80-720 B VOC 3,918 gallons

U519 Oily Water Tank, 3,918 gallons 9 VAC 5-80-720 B VOC 3,918 gallons

U600 Car Wash Tank, 8,000 gallons 9 VAC 5-80-720 B VOC 8,000 gallons

SG401-424 Aqueous Cleaning Chemicals, 18,000 gallons each 9 VAC 5-80-720 B none NA

SG425 H 2 O 2 Tank, 2,000 gallons 9 VAC 5-80-720 B none NA

SG426 Overflow Tank, 1,200 gallons 9 VAC 5-80-720 B none NA

SG427 NH 4 OH Tank, 2,400 gallons 9 VAC 5-80-720 B ammonia NA
SG428 Overflow Tank, 250 gallons 9 VAC 5-80-720 B none NA

SG429-431 Aqueous Cleaning Chemicals, 6,000 gallons each 9 VAC 5-80-720 B none NA

SG432 Aqueous Cleaning Chemicals, 9,000 gallons 9 VAC 5-80-720 B none NA

SG433-434 Aqueous Cleaning Chemicals, 18,000 gallons each 9 VAC 5-80-720 B none NANorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 86
Emission Unit No. Emission Unit Description Citation Pollutant(s) Emitted (9 VAC 5-80-720 B) Rated Capacity (9 VAC 5-80-720 C)

SG435-438 Aqueous Cleaning Chemicals, 4,000 gallons each 9 VAC 5-80-720 B none NA

SG439-440 Overflow, 1,250 gallons each 9 VAC 5-80-720 B none NA

SG441 Overflow, 250 gallons each 9 VAC 5-80-720 B none NA
SG442 Overflow, 100 gallons each 9 VAC 5-80-720 B none NA

SG443-446 Phosphate Water, 18,000 gallons each 9 VAC 5-80-720 B none NA

SG447-449 Portable PO 4 Water, 18,000 gallons each 9 VAC 5-80-720 B none NA

SG452 DI/DEOX water/chilled water, 22,500 gal 9 VAC 5-80-720 B none NA

SG453-455 DI/DEOX water, 18,000 gallons each 9 VAC 5-80-720 B none NA

SG456 Underfloor Collection, 1000 gallons 9 VAC 5-80-720 B none NA

SG457 Dead Leg Collection, 250 gallons 9 VAC 5-80-720 B none NA

SG458 Bleed Tank, 18,000 gallons 9 VAC 5-80-720 B none NA

V700 No. 6 Oil Tank, 124,203 gallons 9 VAC 5-80-720 B VOC NA

V701 No. 6 Oil Tank, 124,203 gallons 9 VAC 5-80-720 B VOC NA

V702 No. 6 Oil Tank, 93,884 gallons 9 VAC 5-80-720 B VOC NA

V703 No. 6 Oil Tank, 93,884 gallons 9 VAC 5-80-720 B VOC NA

V704 No. 6 Oil Tank, 60,373 gallons 9 VAC 5-80-720 B VOC NA

V705 No. 6 Oil Tank, 60,373 gallons 9 VAC 5-80-720 B VOC NA

These emission units are presumed to be in co mpliance with all require ments of the federal Clean Air Act as may apply. Based on this presumption, no monitori ng, recordkeeping, or reporting shall be required for these emissi on units in accordance with 9 VAC 5-80-110.Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 87



### XIII. Permit Shield & Inapplicable Requirements Compliance with the provisions of this pe rmit shall be deemed compliance with all applicable requirements in effect as of the permit issuance date as identified in this permit. This permit shield covers only those app licable requirements covered by terms and conditions in this permit and the following requirements which have been specifically identified as being not applicable to this permitted facility:

Citation Title of Citation Description of Applicability 40 CFR 60 Subpart Kb New Source Performance Standard (NSPS) Requirements for Volatile Organic Liquid Storage Vessels for Which Construction, Reconstruction, or Modification commenced after July 23, 1984 VOL storage tanks, capacity 20,000 to < 40,000 gal with maximum true vapor pressure >=15 kPa (2.16 psi), and capacity >= 40,000 gal with maximum true vapor pressure >=3.5 kPa (0.5 psi). Facility's tanks with the cited capacities have maximum true vapor pressure less than the cited thresholds. 9 VAC 5-40-3410 et seq. (Rule 4-25) Emission Standards For Volatile Organic Compound Storage and Transfer Operations Non-petroleum liquid storage tanks, 40,000 gal capacity or larger, located in a VOC control area (9 VAC 5-20-206). The facility's larger tanks contain petroleum liquids. 40 CFR 63 Subpart T National Emission Standards for Halogenated Solvent Cleaning Solvent cleaning machines containing certain halogenated solvents which are not used at the facility. 40 CFR 63 Subpart X National Emission Standards for Hazardous Air Pollutants from Secondary Lead Smelting Secondary lead smelter using lead-bearing scrap metals. Facility uses pure lead ingots. 40 CFR 60 Subpart IIII Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (ICE ) New, modified, and reconstructed ICE meeting certain size and manufacture date in the rule. 40 CFR 63 Subpart ZZZZ National Emission Standards For Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) RICE at major HAP sources meeting the size and type in the rule.

40 CFR 60 Subpart JJJJ Sta ndards of Performance for Stationary Spark Ignition Internal Combustion Engines (SI ICE) New, modified, and reconstructed SI ICE ordered after June 12, 2006

. Nothing in this permit shield sh all alter the provisions of §303 of the federal Clean Air Act, including the authority of the ad ministrator under that section, the liability of the owner for any violation of applicable requ irements prior to or at the ti me of permit issuance, or the ability to obtain information by the administ rator pursuant to §114 of the federal Clean Air Act, (ii) the Board pursu ant to §10.1-1314 or §10.1-1315 of the Virginia Air Pollution Control Law or (iii) the Department pursu ant to §10.1-1307.3 of the Virginia Air Pollution Control Law.
(9 VAC 5-80-140)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 88 

### XIV. General Conditions

A. Federal Enforceability All terms and conditions in this permit are enforceable by the admi nistrator and citizens under the federal Clean Air Act, except thos e that have been de signated as only stateenforceable.
(9 VAC 5-80-110 N)

B. Permit Expiration This permit has a fixed term of five years. Th e expiration date shall be the date five years from the date of issuance. Unless the owner submits a timely and complete application for renewal to the Department consistent with the requirements of 9 VA C 5-80-80, the right of the facility to operate shall be terminated upon permit expiration.

1. The owner shall submit an application for renewal at least six months but no earlier than eighteen months prior to the date of permit expiration.

2. If an applicant submits a timely and complete application for an initial permit or renewal under this section, the failure of th e source to have a permit or the operation of the source without a permit shall not be a violation of Article 1, Part II of 9 VAC 5 Chapter 80, until the Board takes final ac tion on the application under 9 VAC 5-80- 150.

3. No source shall operate after the time th at it is required to submit a timely and complete application under subsections C and D of 9 VAC 5-80-80 for a renewal permit, except in compliance with a permit issued under Article 1, Part II of 9 VAC 5 Chapter 80.

4. If an applicant submits a timely and comp lete application under section 9 VAC 5-80- 80 for a permit renewal but the Board fails to issue or deny the renewal permit before the end of the term of the previous permit, (i) the previous permit shall not expire until the renewal permit has been issued or denied and (ii) all the terms and conditions of the previous permit, including any permit shield granted pursuant to 9 VAC 5-80-140, shall remain in effect from th e date the application is determined to be complete until the renewal permit is issued or denied.

5. The protection under subsections F 1 and F 5 (ii) of section 9 VAC 5-80-80 F shall cease to apply if, subsequent to the co mpleteness determination made pursuant section 9 VAC 5-80-80 D, the applicant fail s to submit by the deadline specified in writing by the Board any additional information identified as being needed to process the application.

(9 VAC 5-80-80 B, C, and F, 9 VAC 5-80-110 D and 9 VAC 5-80-170 B)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 89 C. Recordkeeping and Reporting

1. All records of monitoring information main tained to demonstrate compliance with the terms and conditions of this permit shall contain, where applicable, the following:

a. The date, place as defined in the permit, and time of sampling or measurements.

b. The date(s) analyses were performed.

c. The company or entity that performed the analyses.

d. The analytical techniques or methods used.

e. The results of such analyses.

f. The operating conditions ex isting at the time of sampling or measurement. (9 VAC 5-80-110 F)

2. Records of all monitoring data and support in formation shall be retained for at least five years from the date of the monito ring sample, measurement, report, or application. Support information includes all calibration and maintenance records and all original strip-chart recordings for continuous m onitoring instrumentation, and copies of all reports required by the permit. (9 VAC 5-80-110 F)

3. The permittee shall submit the results of monitoring contained in any applicable requirement to DEQ no later than March 1 and September 1 of each calendar year. This report must be signed by a responsible official, consistent with 9 VAC 5-80-80 G, and shall include:

a. The time period included in the report. The time periods to be addressed are January 1 to June 30 and July 1 to December 31.

b. All deviations from permit requirements. For purpose of this permit, deviations include, but are not limited to:

(1) Exceedance of emissions limitations or operational restrictions;

(2) Excursions from control device ope rating parameter requirements, as documented by continuous emission m onitoring, periodic monitoring, or Compliance Assurance Monitoring (CAM ) which indicates an exceedance of emission limitations or ope rational restrictions; or,

(3) Failure to meet monitoring, record keeping, or reporting requirements contained in this permit.Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 90

c. If there were no deviations from permit conditions during the time period, the permittee shall include a statement in the report that “no deviations from permit requirements occurred during th is semi-annual reporting period.” (9 VAC 5-80-110 F)

D. Annual Compliance Certification

Exclusive of any reporting required to assure compliance with the te rms and conditions of this permit or as part of a schedule of compliance contained in this permit, the permittee shall submit to EPA and DEQ no later than March 1 each calendar year a certification of compliance with all terms a nd conditions of this permit including emission limitation standards or work practices. The compliance cer tification shall comply with such additional requirements that may be specified pursuant to §114(a)(3) and §504(b) of the federal Clean Air Act. This certification shall be signed by a responsible official, c onsistent with 9 VAC 5- 80-80 G, and shall include:

1. The time period included in the certificati on. The time period to be addressed is January 1 to December 31.

2. The identification of each term or condition of the permit that is the basis of the certification.

3. The compliance status.

4. Whether compliance was continuous or in termittent, and if not continuous, documentation of each incident of non-compliance.

5. Consistent with subsection 9 VAC 5-80- 110 E, the method or methods used for determining the compliance status of the s ource at the time of certification and over the reporting period.

6. Such other facts as the permit may require to determine the compliance status of the

source.

7. One copy of the annual compliance certificati on shall be sent to EPA at the following address: Clean Air Act Title V Compliance Certification (3AP00) U.S. Environmental Protection Agency, Region III 1650 Arch Street Philadelphia, PA 19103-2029 (9 VAC 5-80-110 K.5)

E. Permit Deviation Reporting The permittee shall notify the Director, Tide water Regional Office within four daytime business hours after discovery of any deviati ons from permit requirements which may causeNorthrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 91 excess emissions for more than one hour, includi ng those attributable to upset conditions as may be defined in this permit. In addition, within 14 days of the discovery, the permittee shall provide a written statement explaini ng the problem, any corrective actions or preventative measures taken, and the estimat ed duration of the permit deviation. Owners subject to the requirements of 9 VAC 5-40-50 C and 9 VAC 5-50-50 C are not required to provide the written statement prescribed in this paragraph for facilities subject to the monitoring requirements of 9 VAC 5-40-40 and 9 VAC 5-50-40. The occurrence should also be reported in the next semi-annual complia nce monitoring report pursuant to General Condition XIV.C.3 of this permit.
(9 VAC 5-80-110 F.2 and 9 VAC 5-80-250)

F. Failure/Malfunction Reporting In the event that any affected facility or related air pollu tion control equipment fails or malfunctions in such a manner that may cause excess emissions for more than one hour, the owner shall, as soon as practicable but no la ter than four daytime business hours after the malfunction is discovered, no tify the Director, Tidewater Regional Office by facsimile transmission, telephone or telegr aph of such failure or malfunc tion and shall within 14 days of discovery provide a written statement giving all pertinent facts, including the estimated duration of the breakdown. Owners subject to the requirements of 9 VAC 5-40-50 C and 9 VAC 5-50-50 C are not required to provide the writt en statement prescribed in this paragraph for facilities subject to the monitoring requi rements of 9 VAC 5-40-40 and 9 VAC 5-50-40. When the condition causing the failure or malf unction has been corrected and the equipment is again in operation, the owner shall notif y the Director, Tidewater Regional Office.

1. The emission units that have continuous m onitors subject to 9 VAC 5-40-50 C and 9 VAC 5-50-50 C are not subject to the 14 day written notification.

2. The emission units subject to the reporti ng and the procedure re quirements of 9 VAC 5-40-50 C and the procedures of 9 VAC 5-50-50 C are listed below:

a. Boilers TS-E1 and E2,

b. Argon Oxygen Degassing Unit (550-E1), Sa nd Reclaim Operation (555-E11), and New Sand Operation (555-E1) of the Foundry Operation,

c. The heat cleaning oven of the Powder Coating Operation (206-C1), and

d. The Arc Gouger (250-E2).Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 92

3. Each owner required to install a continuous monitoring system (CMS) or monitoring device subject to 9 VAC 5-40-41 or 9 VAC 5-50-410 shall submit a written report of excess emissions (as defined in the applicab le subpart in 9 VAC 5-50-410) and either a monitoring systems performance report or a summary report form, or both, to the board quarterly for the NOx CEMS of the boilers TS-E1 and E2, and semiannually for the other monitors. All quarterly reports shall be postmarked by the 30 th day following the end of each cale ndar quarter, and all semi -annual reports shall be postmarked by the 30 th day following the end of each calendar semi-annual period (June 30 th and January 30 th ). All reports shall include the following information:

a. The magnitude of excess emissions computed in accordance with 40 CFR 60.13(h) or 9 VAC 5-40-41 B .6, any conversion factors used, and the date and time of commencement and completion of each period of excess emissions;

b. Specific identification of each period of excess emissions that occurs during startups, shutdowns, and malfunctions of th e source. The nature and cause of any malfunction (if known), the corrective act ion taken or preventative measures adopted;

c. The date and time identifying each period during which the continuous monitoring system was inoperative except for zero and span checks and the nature of the system repairs or adjustments; and

d. When no excess emissions have occurred or the continuous monitoring systems have not been inoperative, repaired or adju sted, such information shall be stated in the report.
All malfunctions of emission units not s ubject to 9 VAC 5-40 -50 C and 9 VAC 5-50- 50 C require written reports within 14 days of the di scovery of the malfunction. (9 VAC 5-20-180 C, 9 VAC 5-40-50, and 9 VAC 5-50-50)

G. Severability The terms of this permit are severable. If a ny condition, requirement or portion of the permit is held invalid or inapplicable under any circumstance, such inva lidity or inapplicability shall not affect or impair the remaining conditions , requirements, or portions of the permit.
(9 VAC 5-80-110 G.1)

H. Duty to Comply The permittee shall comply with all terms a nd conditions of this permit. Any permit noncompliance constitutes a viol ation of the federal Clean Ai r Act or the Virginia Air Pollution Control Law or both and is ground for enforcement action; for permit termination, revocation and reissuance, or modification; or , for denial of a permit renewal application.
(9 VAC 5-80-110 G.2)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 93 I. Need to Halt or Reduce Activity not a Defense It shall not be a defense for a permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit.
(9 VAC 5-80-110 G.3)

J.Permit Modification A physical change in, or change in the method of operation of, this stationary source may be subject to permitting under State Regulati ons 9 VAC 5-80-50, 9 VAC 5-80-1100, 9 VAC 5- 80-1605, or 9 VAC 5-80-2000 and ma y require a permit modificati on and/or revisions except as may be authorized in any appr oved alternative operating scenarios.
(9 VAC 5-80-190 and 9 VAC 5-80-260)

K. Property Rights The permit does not convey any property rights of any sort, or any exclusive privilege.
(9 VAC 5-80-110 G.5)

L. Duty to Submit Information

1. The permittee shall furnish to the Board, within a reasonable time, any information that the Board may request in writing to determine whether cause exists for modifying, revoking and reissuing, or term inating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the Board copies of records required to be kept by the permit and, for information claimed to be confidential, the permittee shal l furnish such records to the Board along with a claim of confidentiality. (9 VAC 5-80-110 G.6)

2. Any document (including reports) required in a permit condition to be submitted to the Board shall contain a certification by a responsible official that meets the requirements of 9 VAC 5-80-80 G. (9 VAC 5-80-110 K.1)

M. Duty to Pay Permit Fees The owner of any source for which a permit under 9 VAC 5-80-50 through 9 VAC 5-80-300 was issued shall pay permit fees consiste nt with the requirements of 9 VAC 5-80-310 through 9 VAC 5-80-350. The actual emissions c overed by the permit program fees for the preceding year shall be calculated by the owner and submitted to the Department by April 15 of each year. The calculations and final amount of emissions are subject to verification and final determination by the Department.
(9 VAC 5-80-110 H and 9 VAC 5-80-340 C)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 94 N. Fugitive Dust Emission Standards During the operation of a stationary source or any other building, stru cture, facility, or installation, no owner or other pe rson shall cause or permit any materials or property to be handled, transported, stored, used, constructe d, altered, repaired, or demolished without taking reasonable precautions to prevent par ticulate matter from becoming airborne. Such reasonable precautions may include, but are not limited to, the following:

1. Use, where possible, of water or chemical s for control of dust in the demolition of existing buildings or structur es, construction operations, the grading of roads, or the clearing of land;

2. Application of asphalt, wate r, or suitable chemicals on dirt roads, materials stockpiles, and other surfaces which may creat e airborne dust; the paving of roadways and the maintaining of them in a clean condition;

3. Installation and use of hoods, fans, and fabric filters to enclose and vent the handling of dusty material. Adequate contai nment methods shall be employed during sandblasting or similar operations;

4. Open equipment for conveying or transporti ng material likely to create objectionable air pollution when airborne sh all be covered or treated in an equally effective manner at all times when in motion; and,

5. The prompt removal of spilled or tracked di rt or other materials from paved streets and of dried sediments resulting from soil erosion. (9 VAC 5-40-90 and 9 VAC 5-50-90)

O. Startup, Shutdown, and Malfunction At all times, including periods of startup, shutdown, and soot bl owing, and malfunction, owners shall, to the extent pr acticable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with air pollution control practices for minimizing emissions. Determ ination of whether acc eptable operating and maintenance procedures are being used will be based on information available to the Board, which may include, but is not limited to, monitori ng results, opacity observations, review of operating and maintenance procedures , and inspection of the source. (9 VAC 5-50-20 E and 9 VAC 5-40-20 E)

P. Alternative Operating Scenarios Contemporaneously with making a change between reasonably anticipated operating scenarios identified in this permit, the permittee shall record in a log at the permitted facility a record of the scenario under which it is oper ating. The permit shield described in 9 VAC 5- 80-140 shall extend to all terms and conditions under each such operating scenario. The terms and conditions of each such alternative s cenario shall meet all applicable requirements including the requirements of 9 VAC 5 Chapter 80, Article 1.
(9 VAC 5-80-110 J)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 95 Q. Inspection and Entry Requirements The permittee shall allow DEQ, upon presentation of credentials and other documents as may be required by law, to perform the following:

1. Enter upon the premises where the source is located or emissions -related activity is conducted, or where records must be kept under the terms and conditions of the permit.

2. Have access to and copy, at reasonable times, any records that must be kept under the terms and conditions of the permit.

3. Inspect at reasonable times any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit.

4. Sample or monitor at reasonable times subs tances or parameters for the purpose of assuring compliance with the perm it or applicable requirements. (9 VAC 5-80-110 K.2)

R. Reopening For Cause The permit shall be reopened by the Board if additional federal requirements become applicable to a major source with a remaining permit term of three years or more. Such reopening shall be completed no later than 18 m onths after promulgation of the applicable requirement. No such reopening is required if th e effective date of the requirement is later than the date on which the permit is due to expire, unless the original permit or any of its terms and conditions has been extended pursuant to 9 VAC 5-80-80 F.

1. The permit shall be reopened if the Board or the administrator determines that the permit contains a material mistake or th at inaccurate statements were made in establishing the emissions st andards or other terms or conditions of the permit.

2. The permit shall be reopened if the administrator or the Board determines that the permit must be revised or revoked to a ssure compliance with the applicable requirements.

3. The permit shall not be reopened by the Board if additional applicable state requirements become applicable to a majo r source prior to the expiration date established under 9 VAC 5-80-110 D. (9 VAC 5-80-110 L)

S. Permit Availability Within five days after receipt of the issued permit, the perm ittee shall maintain the permit on the premises for which the permit has been i ssued and shall make the permit immediately available to DEQ upon request.
(9 VAC 5-80-150 E)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 96 T. Transfer of Permits

1. No person shall transfer a permit from one location to another, unless authorized under 9 VAC 5-80-130, or from one piece of equipment to another. (9 VAC 5-80-160)

2. In the case of a transfer of ownership of a stationary source, the new owner shall comply with any current permit issued to the previous owner. The new owner shall notify the Board of the change in ownership within 30 days of the transfer and shall comply with the requirements of 9 VAC 5-80-200. (9 VAC 5-80-160)

3. In the case of a name change of a stationa ry source, the owner shall comply with any current permit issued under the previous source name. The owner shall notify the Board of the change in source name within 30 days of the name change and shall comply with the requirements of 9 VAC 5-80-200. (9 VAC 5-80-160)

U. Malfunction as an Affirmative Defense

1. A malfunction constitutes an affirma tive defense to an action brought for noncompliance with technology-based emissi on limitations if the requirements of paragraph 2 of this condition are met.

2. The affirmative defense of malfunction shall be demonstrated by the permittee through properly signed, contemporaneous ope rating logs, or other relevant evidence that show the following:

a. A malfunction occurred and the permittee ca n identify the cause or causes of the malfunction.

b. The permitted facility was at the time being properly operated.

c. During the period of the malfunction the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit.Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 97

d. The permittee notified the Board of the malfunction within two working days following the time when the emission limitations were exceeded due to the malfunction. This notification shall incl ude a description of the malfunction, any steps taken to mitigate emissions, and corrective actions taken. The notification may be delivered either orally or in wr iting. The notification may be delivered by electronic mail, facsimile transmission, telephone, or any other method that allows the permittee to comply with the d eadline. This notification fulfills the requirements of 9 VAC 5-80-110 F.2.b to re port promptly deviations from permit requirements. This notification does not release the permittee from the malfunction reporting requirement under 9 VAC 5-20-180 C.

3. In any enforcement proceeding, the permittee seeking to establish the occurrence of a malfunction shall have the burden of proof.

4. The provisions of this section are in addi tion to any malfunction, emergency or upset provision contained in any applicable requirement. (9 VAC 5-80-250)

V. Permit Revocation or Termination for Cause A permit may be revoked or terminated prior to its expiration date if the owner knowingly makes material misstatements in the permit appl ication or any amendments thereto or if the permittee violates, fails, neglects or refuses to comply with the term s or conditions of the permit, any applicable requirements, or the applicable provisions of 9 VAC 5 Chapter 80 Article 1. The Board may suspend, under such conditions and for such period of time as the Board may prescribe any permit for any grounds for revocation or termination or for any other violations of these regulations.
(9 VAC 5-80-190 C and 9 VAC 5-80-260)

W. Duty to Supplement or Correct Application Any applicant who fails to submit any relevant facts or who has submitted incorrect information in a permit application shall, upon becoming aware of such failure or incorrect submittal, promptly submit such supplementary f acts or corrections. An applicant shall also provide additional information as necessary to address any requirements that become applicable to the source after the date a comple te application was filed but prior to release of a draft permit.
(9 VAC 5-80-80 E)

X. Stratospheric Ozone Protection If the permittee handles or emits one or more Cl ass I or II substances subject to a standard promulgated under or established by Title VI (S tratospheric Ozone Protection) of the federal Clean Air Act, the permittee shall comply with all applicable sections of 40 CFR Part 82, Subparts A to F. (40 CFR Part 82, Subparts A-F)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 98 Y. Asbestos Requirements The permittee shall comply with the require ments of National Emissions Standards for Hazardous Air Pollutants (40 CFR 61) Subpart M, National Emission Standards for Asbestos as it applies to the following: Standard s for Demolition and Renovation (40 CFR 61.145), Standards for Insulating Materials (40 CFR 61.1 48), and Standards for Waste Disposal (40 CFR 61.150).
(9 VAC 5-60-70 and 9 VAC 5-80-110 A.1)

Z. Accidental Release Prevention If the permittee has more, or will have more than a threshold quantity of a regulated substance in a process, as determined by 40 CFR 68.115, the permittee shall comply with the requirements of 40 CFR Part 68.
(40 CFR Part 68)

AA. Changes to Permits for Emissions Trading No permit revision shall be required under a ny federally approved economic incentives, marketable permits, emissions trading and othe r similar programs or processes for changes that are provided for in this permit.
(9 VAC 5-80-110 I)

BB. Emissions Trading Where the trading of emissions increases and d ecreases within the permitted facility is to occur within the context of this permit and to the extent that the regulations provide for trading such increases and d ecreases without a case-by-case approval of each emissions trade:

1. All terms and conditions required under 9 VAC 5-80-110, except subsection N, shall be included to determine compliance.

2. The permit shield described in 9 VAC 5-80-140 shall extend to all terms and conditions that allow such increas es and decreases in emissions.

3. The owner shall meet all applicable requi rements including the requirements of 9 VAC 5-80-50 through 9 VAC 5-80-300. (9 VAC 5-80-110 I)Northrop Grumman Shipbuilding, Inc. Permit Number: TRO-60153 Effective Date: June 1, 2009 Page 99


### XV. State-Only Enforceable Requirements The following terms and conditions are not requ ired under the federal Clean Air Act or under any of its applicable federal re quirements, and are not subject to the requirements of 9 VAC 5-80-290 concerning review of proposed permits by EPA and draft permits by affected states.

1. The facility is subject to the Emission Sta ndards for Odor in 9 VAC 5-40-130 et seq. (Rule 4-2), and the Standards of Performa nce for Odorous Emissions in 9 VAC 5-50- 130 et seq. (Rule 5-2).

2. The facility is subject to the Emission St andards for Toxics Pollutants from Existing Sources in 9 VAC 5-60-200 et seq. (Rul e 6-4), and the Emission Standards for Toxics Pollutants from New and Modified Sources in 9 VAC 5-60-300 et seq. (Rule 6-5).

(9 VAC 5-80-110 N and 9 VAC 5-80-300)