Federal Operating Permit 

Article 1 

This permit is based upon the requirements of Title V of the Federal Clean Air Act and Chapter 80, 

Article 1 of the Commonwealth of Virginia Regulations for the Control and Abatement of Air 

Pollution. Until such time as this permit is reopened 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 authority of Title 10.1, Chapter 13, §10.1-1322 of the Air 

Pollution Control Law of Virginia. This permit is issued consistent with the Administrative Process 

Act, and 9 VAC 5-80-50 through 9 VAC 5-80-300 of the State Air Pollution Control Board 

Regulations for the Control and Abatement of Air Pollution of the Commonwealth of Virginia. 

Authorization to operate a Stationary 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 - Clean Air Act (Sections I through XIV) 

State-Only Enforceable Requirements (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 4-99
Northrop Grumman Shipbuilding, Inc. 

Permit Number: TRO-60153 

June 1, 2009 

Page 2 

Table of Contents

I. FACILITY INFORMATION .......................................................................................................4

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

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

A. LIMITATIONS..............................................................................................................................................25 

B. MONITORING..............................................................................................................................................29 

C. RECORDKEEPING........................................................................................................................................31 

D. TESTING .....................................................................................................................................................33 

E. NOTIFICATIONS AND REPORTING ..............................................................................................................33 

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

A. LIMITATIONS..............................................................................................................................................35 

B. MONITORING..............................................................................................................................................37 

C. RECORDKEEPING........................................................................................................................................45 

D. TESTING .....................................................................................................................................................46 

E. NOTIFICATIONS AND REPORTING ..............................................................................................................49 

V. STEEL PREPARATION AND FABRICATION REQUIREMENTS....................................50

A. LIMITATIONS..............................................................................................................................................50 

B. MONITORING..............................................................................................................................................51 

C. RECORDKEEPING........................................................................................................................................51 

D. TESTING .....................................................................................................................................................52 

VI. SECONDARY LEAD PROCESSING REQUIREMENTS......................................................52

A. LIMITATIONS..............................................................................................................................................52 

B. MONITORING..............................................................................................................................................53 

C. RECORDKEEPING........................................................................................................................................54 

D. TESTING .....................................................................................................................................................54 

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

A. LIMITATIONS..............................................................................................................................................55 

B. MONITORING..............................................................................................................................................56 

C. RECORDKEEPING........................................................................................................................................56 

D. TESTING .....................................................................................................................................................56 

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

A. LIMITATIONS..............................................................................................................................................57 

B. MONITORING..............................................................................................................................................58 

C. RECORDKEEPING........................................................................................................................................59 

D. TESTING .....................................................................................................................................................59 

E. REPORTING ................................................................................................................................................60 

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

A. LIMITATIONS..............................................................................................................................................61 

B. MONITORING AND RECORDKEEPING .........................................................................................................65 

C. TESTING .....................................................................................................................................................68 

D. REPORTING ................................................................................................................................................68 
Northrop Grumman Shipbuilding, Inc. 

Permit Number: TRO-60153 

June 1, 2009 

Page 3 

X. SPECIALTY SHOPS REQUIREMENTS.................................................................................69

A. LIMITATIONS..............................................................................................................................................69 

B. MONITORING..............................................................................................................................................71 

C. RECORDKEEPING........................................................................................................................................71 

D. TESTING .....................................................................................................................................................72 

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

A. LIMITATIONS..............................................................................................................................................72 

B. MONITORING..............................................................................................................................................74 

C. RECORDKEEPING........................................................................................................................................76 

D. TESTING .....................................................................................................................................................76 

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

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

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

A. FEDERAL ENFORCEABILITY .......................................................................................................................88 

B. PERMIT EXPIRATION ..................................................................................................................................88 

C. RECORDKEEPING AND REPORTING ............................................................................................................89 

D. ANNUAL COMPLIANCE CERTIFICATION.....................................................................................................90 

E. PERMIT DEVIATION REPORTING ................................................................................................................90 

F. FAILURE/MALFUNCTION REPORTING ........................................................................................................91 

G. SEVERABILITY ...........................................................................................................................................92 

H. DUTY TO COMPLY......................................................................................................................................92 

I. NEED TO HALT OR REDUCE ACTIVITY NOT A DEFENSE ............................................................................93 

J. PERMIT MODIFICATION .............................................................................................................................93

K. PROPERTY RIGHTS .....................................................................................................................................93 

L. DUTY TO SUBMIT INFORMATION ...............................................................................................................93 

M. DUTY TO PAY PERMIT FEES.......................................................................................................................93 

N. FUGITIVE DUST EMISSION STANDARDS ....................................................................................................94 

O. STARTUP, SHUTDOWN, AND MALFUNCTION .............................................................................................94 

P. ALTERNATIVE OPERATING SCENARIOS.....................................................................................................94 

Q. INSPECTION AND ENTRY REQUIREMENTS .................................................................................................95 

R. REOPENING FOR CAUSE.............................................................................................................................95

S. PERMIT AVAILABILITY ..............................................................................................................................95 

T. TRANSFER OF PERMITS ..............................................................................................................................96 

U. MALFUNCTION AS AN AFFIRMATIVE DEFENSE .........................................................................................96 

V. PERMIT REVOCATION OR TERMINATION FOR CAUSE ................................................................................97 

W. DUTY TO SUPPLEMENT OR CORRECT APPLICATION..................................................................................97 

X. STRATOSPHERIC OZONE PROTECTION.......................................................................................................97 

Y. ASBESTOS REQUIREMENTS........................................................................................................................98 

Z. ACCIDENTAL RELEASE PREVENTION.........................................................................................................98 

AA. CHANGES TO PERMITS FOR EMISSIONS TRADING......................................................................................98 

BB. EMISSIONS TRADING..................................................................................................................................98 

XV. STATE-ONLY ENFORCEABLE REQUIREMENTS.............................................................99
Northrop Grumman Shipbuilding, Inc. 

Permit Number: TRO-60153 

Effective Date: June 1, 2009 

Page 4 

I. Facility Information 

Permittee 

Northrop Grumman Shipbuilding, Inc. (NGSB, formerly 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, Health 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 classified as a major source for criteria and hazardous 

air pollutant emissions from its various operations. It is therefore subject to Title V operating 

permit requirements. Products manufactured include U.S. Navy contracted aircraft carriers and 

submarines, as well as ships for commercial applications such as oil tankers and service ships. 

Services performed at the facility include all activities related to the repair, overhaul, and 

conversion of ships. The facility can be divided 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 oil. 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 Fabrication Operation, the 
Northrop Grumman Shipbuilding, Inc. 

Permit Number: TRO-60153 

Effective Date: June 1, 2009 

Page 5 

Foundry Operation, and Miscellaneous Activities, however, they are addressed under Fuel 

Burning Equipment. The facility also uses a number 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 qualify as insignificant activities; 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 facility foundries for a full range of castings necessary for the 

construction/repair of ships. Foundry operations generally include the following processes: 

melting, casting, finishing, and sand handling. Alloying 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 castings are separated from the molds at shakeout. The sand is 

recovered while the castings move to the finishing area. Finishing involves removal of 

extraneous metal by burning-off, blasting, and grinding. The facility also has a pattern shop to 

develop and refine the large and complex patterns 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 resin, 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 specific internal voids (for example, 

recessed curves and hollow areas). The foundry uses 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 particulate 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 same building as the EAFs, not subject to the 

MACT but subject to Compliance Assurance Monitoring (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 computer-controlled temperature and humidity to prevent 

"flash rust" corrosion on freshly 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. Emissions 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/shearing, cold and hot forming, planing/milling, 

punching/drilling, and sawing. The steel production facility is an eleven acre complex for the 

fabrication of structural steel, ranging from small components to complex 300-ton ship 

subassemblies. Operations include plate preparation, flame planers, automated panel line, web 

lines, numerically controlled burning machines, flat and curved block shops, and machinery for 

assembly of circular hull plates. Plate preparation includes some shot blasting and heating to 

prepare the surface for the next step 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 utilized. The process involves 
Northrop 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 process heating. Particulate and lead emissions are controlled by 

baghouses. 

 

Woodworking Operations - Woodworking operations associated with the facility's primary 

function, shipbuilding, generally occur at two locations. Building No. 3 primarily makes pallets, 

boxes, and shoring timbers. Equipment used includes 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 wood, plastic, or Plexiglas. Fullscale models of these materials are used as training aids, for demonstrations, or for verification 

of design. Wood is also used to make some mold patterns on the second floor of Building 501 

and produce pallets and shipping containers at Building 513. Particulate emissions are controlled 

by cyclones. 

 

Electroplating - The electroplating plant performs chrome, 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 characteristics, wear resistance and hardness, and specific 

electrical properties for ship hardware and parts. The facility is subject to the MACT of 40 CFR 

63 Subpart N- National Emission Standards for Chromium Emissions from Hard and Decorative 

Chromium Electroplating and 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 facility's primary function, shipbuilding, occur at 

various locations throughout the facility. Paint booths are located in the fabrication areas and 

numerous shops (e.g., machine, electric, and hull outfitting). Outside painting occurs in areas 

such as dry docks, assembly platens, Quonset huts, in the open, under extemporaneous or semiportable cover, inside, and outside of buildings. Brush, roller, spray, and touch-up painting 

applications for vessel or non-vessel related items also occur in many operational areas. Paints 

are generally purchased in small containers (1 to 5 gallons) and then mixed (thinned, if needed) 

in 5 to 10-gallon paint pots. These 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 cleaning 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 facility can more effectively meet 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 with water wash curtains, associated with the 

aluminum flame spray facility. The facility also 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 locations at the facility. Work at the 

various machine shops involves metal cleaning, machining, and fabrication of large plates, 

smaller parts, pipe cutting, and similar activities. Several buildings house very large lathes and 

milling equipment for turning large metal plates and other large parts. 

Piping is fabricated and assembled at the pipe fabrication facility. Equipment includes horizontal 

boring mills, standard and radial drill presses, lathes, automatic welding machines, standard pipe 

bending machines, a variable radius pipe roller-bender, pipe threaders, etc. Metal machining and 

surface preparation are also performed at the pipe fabrication facility. 

Electrical shops are located at several locations at the facility, manufacturing, maintaining, 

testing and repairing electrical equipment of all sizes. 

While the above operations handle metal parts, plastic components are processed by the 

melamine operations. 

Particulate emissions are exhausted to cyclones or baghouses. 

There are also facility-wide parts washer operations that use cleaning solvents that have been 

determined not subject to 40 CFR Part 63 Subpart 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 installation applications, vessel 

cleaning, radionuclides, general plant activities (welding, sandblasting, general carpentry, 

cleaning, vehicle maintenance, offset printing, blueprinting, copying, and firefighting), two 

gasoline service stations, and research and development activities. Facility-wide abrasive 

blasting, grit off-loading, and welding/brazing 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 dated 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 from <1,000 gallons up to 500,000 gallons are 

located at the facility. Most tanks are used for storage of petroleum related materials including 

No. 6 fuel oil, diesel oil, waste oil, and oily wastewater. Some process related storage tanks are 

pressurized, e.g., varnish tanks. Totes (200 to 400 gallons), 55-gallon drums, and pots (5 to 10 

gallons) are used for painting activities. 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-gallon 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 through 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 Grum

Perm

Effec

II. Emission Units Equipment to be operated consists of: Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

Fuel Burning Equipment/ Steam Boilers 

FTSF-E1 FTSF-S1 

No. 6 fuel oil-fired 

barge- mounted boiler, 

Combustion 

Engineering Model 

V2M-8, pre-1983 

213.26 

MMBTU/hr _ _ 

FTSF-E2 FTSF-S2 

No. 6 fuel oil-fired 

barge- mounted boiler, 

Combustion 

Engineering Model 

V2M-8, pre-1983 

213.26 

MMBTU/hr _ _ 

78-E1 78-S1 

No. 6 fuel oil or 

recovered oil-fired 

boiler, B&W Integral 

Furnace, 1948 

135 MMBTU/hr _ _ 

78-E2 78-S1 

No. 6 fuel oil or 

recovered oil-fired 

boiler, B&W Integral 

Furnace, 1948 

135 MMBTU/hr _ _ 

78-E3 78-S1 

No. 6 fuel oil or 

recovered oil-fired 

boiler, B&W Integral 

Furnace, 1948 

135 MMBTU/hr _ _ 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

TS-E1 TS-S1 No. 2 fuel oil, manufactured 1994 245.3 MMBTU/hr Low NOx Burner _ NTS-E2 TS-S2 No. 2 fuel oil, manufactured 1997 245.3 MMBTU/hr Low NOx Burner _ N

Fuel Burning Equipment/ Steel Preparation and Fabrication 

276-E1 276-S1 

Propane-fired oven, 

construction date 

unknown 

15.3 MMBTU/hr _ _ 

276-E2 276-S2 

Propane-fired Ray 

Campbell Furnace, 

construction date 

unknown 

15.4 MMBTU/hr _ _ 

Fuel Burning Equipment/ Foundry 

550-E8 550-S8 Propane-fired heat treating furnace # 5784 15.3 MMBTU/hr _ _ 550-E9 550-S9 Propane-fired heat treating furnace # 5302 27 MMBTU/hr _ _ 

550-E13 550-S13 Propane-fired heat treating furnace #57531 12 MMBTU/hr _ _ 

Fuel Burning Equipment/ Miscellaneous Activities 

1278-E1 1278-S1 Annealing oven- Northside, #2 oil 20.79 MMBTU/hr _ _ 

36-38152 _ Generator, stationary, Nancy Lee, diesel 672 HP _ _ 

76-4179 _ Generator B905, diesel 672 HP _ _ 
Northrop Grum

Perm

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Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

1-35058 _ Generator, portable, diesel 740 HP _ _ 2-35060 _ Generator, portable, diesel 740 HP _ _ 

60-40340 _ Generator, portable transfer car, diesel 740 HP _ _ 

23 - 91090 _ Generator, stationary DD12 B1753, diesel 759 HP _ _ 11 - 41703 _ Generator, MOS Boiler Operations, diesel 980 HP _ _ 

17 - 35738 _ Generator, portable, diesel 980 HP _ _ 21 - 71128 _ Generator, stationary PL 13 SGCC, diesel 1620 HP _ _ 34 - 36859 _ Generator, stationary B4636, diesel 1479 HP _ _ 58 - 39934 _ Generator, stationary FDD port, diesel 1479 HP _ _ 59 - 40005 _ Generator, stationary FDD STBD, diesel 1479 HP _ _ 

42030, 42031, 42032, 42033, 42302, 42303, 42304, 42305, 42306, 42307, 

42308 

_ 

Eleven (11) Sullair 1300, Caterpillar diesel engine / model 3406, diesel 

480 HP each _ _ 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

Foundry Operations 

550-E1 

Argon/Oxygen Degassing Furnace, Whiting Corporation 

25 ton/hr 

550-E2 Electric Arc Furnace A 3 ton/hr 550-E3 Electric Arc Furnace B 3 ton/hr 550-E4 Electric Arc Furnace C 3 ton/hr 

550-E12 

550-S1 

Riser Burn Booth, hand torches 0.068 ton/hr 

Cartridge Filter system, Donaldson Torit- Downflo Oval 4-128, 99.9% design control efficiency 

550-C1a 

550-EF1 _ Charging/Tapping Operations 12.5 ton/hr _ _ 550-EF2 _ Pouring casting/Casting cooling Operation 25 ton/hr _ _ 550-EF5 _ Shakeout Operations NA _ _ 

550-E10 _ Abrasive Saw, #5453 0.02 tons/hr Dust collector venting inside the building _ 550-E20 550-S20 Steel Shot Abrasive Blasting, #5610 6 tons/hr Baghouse, 95% design control efficiency 550-C20 550-E21 550-S21 Sawing operation, #5616 0.01 tons/hr Cyclone, 70% design control efficiency 550-C21 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

555-E11 Sand Reclaim Operations, hopper 12.5 tons/hr 

555-EF3 

555-S11 

Riser Burn Area, #34561, hand torches 0.068 ton/hr 

Baghouse, Standard 

Havens Alpha Mark 

III, size 24 SH, 

#34561, 95% design 

control efficiency 

555-C11 

555-E1 555-S1 New Sand Operations, #40645, hopper 100 tons/hr 

Cartridge filters, 

Torit 2DF12 

Downflow, #40645, 

99% design control 

efficiency 

555-C1 

528-EF1 _ Abrasive Blasting 50 lbs/hr _ _ 528-EF2 _ Riser Burn Area NA _ _ 556-EF1 _ Electric Induction Furnaces (4 each) 0.5 to 4 tons _ _ 556-EF2 _ Gas Furnace 90 Lbs _ _ 556-EF3 _ Pouring casting/Casting cooling Operation 4 ton/hr _ _ 

Steel Preparation and Fabrication Operations 

1746-E1 1476-S1 

Abrasive Blasting- Steel Shots, Pangborn Rotoblast 

2.5 tons/hr 

Pangborn Dust 

Collector, 95% design 

control efficiency 

1746-C1 

274-E1 274-S1 Abrasive Shot Blasting 2.5 tons/hr 

Wheelabrator #19, Model 126D, 95% 

design control 

efficiency 

274-C1 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

275-E5 275-S5 Abrasive Shot Blasting 2.5 tons/hr 

Pangborn C70, Type 

CM, 95% design 

control efficiency 

275-C5 

276-E3 276-S3 Wire Brush Paint Removal _ 

Torit dust collector, 

Downflow DFT4-16 

cartridge filter, 99% 

design control 

efficiency 

276-C3 

276-E3PC Building vents Plasma Cutting _ _ _ 

288-E1 288-S1 Abrasive Blasting- Steel shots 2.5 tons/hr RF Cox Associates baghouse, 95% design control efficiency 288-C1 288-E2 288-S2 Abrasive Blasting- Steel shots 2.5 tons/hr RF Cox Associates baghouse, 95% design control efficiency 288-C2 288-E3 288-S3 Abrasive Blasting- Steel shots 2.5 tons/hr RF Cox Associates baghouse, 95% design control efficiency 288-C3 288-E4 288-S4 Abrasive Blasting- Steel shots 2.5 tons/hr RF Cox Associates baghouse, 95% design control efficiency 288-C4 

Secondary Lead Processing 

4582-E1 through 

E6 4582-S1 Lead Contouring Hot Benches 4.7 tons/hr combined 

Baghouse, Standard Havens Alpha Mark III 18, 99.0% design control efficiency 

4582-C1 
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Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

4582-E12 4582-S2 Lead Casting Furnaces and Conveyor System 4.7 tons/hr 

Baghouse, Standard Havens Alpha Mark III 18, 99.0% design control efficiency 

4582-C2 

LS-E1 4582-S3 

Lead School (for training) with 3 work stations 

0.05 tons/hr 

Baghouse, Standard Havens Alpha Mark III 18, 99.0% design control efficiency 

4582-C3 

Wood Working 

3-E1 3-S1 Cutting/Planer/Re-saw _ 

Cyclone, 90.0% 

design control 

efficiency 

3-C1 

501-E2 501-S2 Foundry Pattern Shop - wood cutting machines _ Cyclone, 90.0% design control efficiency 501-C2 513-E1 513-S1 Warehouse No. 6 Saws _ 

Cyclone, 90.0% 

design control 

efficiency 

513-C1 

Electroplating

PLATE-E1 

Chromium 

electroplating tank #63, 

Plateg Corp., POP68919-R 129 ft3/hour 

PLATE-E2 

Chromium 

electroplating tank #49, 

Plateg Corp., POP68919-R 32 ft3/hour 

PLATE-E3 

4620-S1 

Chromium 

electroplating tank #59, 

Plateg Corp., POP68919-R 129 ft3/hour 

Zenon packed tower scrubber, 98.0% design control efficiency 

4620-C1 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

Painting Operations Painting Operations/Group P-X33

232-E1 through 

E6 

232-S1 through S6 

Consolidated Paint Facility, 2 banks of 3 paint booths each (6 total) 

_ 

Binks 

Dynaprecipitator, 

water wash curtain, 

98% design control 

efficiency 

232-C1 through 

C6 PM-1

4681-E2 4681-S2 

Metal Finishing Bldg, paint booth (Zn phosphate coating line), automated 

_ 

Greenline 

Corporation, water 

wash curtain, 98% 

design control 

efficiency 

4681-C2 PM-1

4681-E3 4681-S3 Metal Finishing Bldg, paint booth, manual _ 

Greenline 

Corporation, water 

wash curtain, 98% 

design control 

efficiency 

4681-C3 PM-1

4701-E10 4701-S10 Aluminum Wire Flame Spray booth, manual _ 

Global Finishing 

Solutions water wash 

curtains, 98% design 

control efficiency 

4701-C10 PM-1

4701-E11 4701-S11 Aluminum Wire Flame Spray booth, manual _ 

Global Finishing 

Solutions water wash 

curtains, 98% design 

control efficiency 

4701-C11 PM-1

4701-E12 4701-S12 

Flame Spray Facility paint booth, north unit, manual 

_ 

Global Finishing 

Solutions water wash 

curtains, 98% design 

control efficiency 

4701-C12 PM-1
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

4701-E13 4701-S13 

Flame Spray Facility paint booth, south unit, manual 

_ 

Global Finishing 

Solutions water wash 

curtains, 98% design 

control efficiency 

efficiency 

4701-C13 PM-1

4702-E1 4702-S1 Paint Spray Bldg, antenna paint booth _ 

Filter (paper), JBI 

Automatic Spray 

Booth, 90% design 

control efficiency 

4702-C1 PM-1

4730-NP 4730-NPFE 

Grit Blast & Paint Facility, North Paint Room 

_ 

Filter (paper), 90% 

design control 

efficiency 

4730-NPC PM-1

4730-SP 4730-SPFE 

Grit Blast & Paint Facility, South Paint Room 

_ 

Filter (paper), 90% 

design control 

efficiency 

4730-SPC PM-1

Painting Operations/P-SHIPSPRAY

P-SHIPSPRAY _ Outside Vessel Painting- manual spray painting _ _ _ 

Painting Operations/P-SHIPBRUSH

P-SHIPBRUSH _ 

General facility-wide marine coating operations, brush, roller, and touch-up application on vessels and vessel parts- manual brush painting 

_ _ _ 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

Painting Operations/Powder Coating Operation 

205-C1a 

205-C1b 

205-C1c 

205-C1aS 

205-C1bS 

205-C1cS 

Parts Washer with three burners, natural gas-fired, Eclipse Imersojet IJ6 

One burner rated at 2.0 MMBTU/hr and two burners rated at 1.3 MMBTU/hr each 

_ _ 

205-C2 205-C2S 

Preheat oven, natural gas-fired, Eclipse AH520 

Burner and 

evaporator rated 

at 5.5 

MMBTU/hr 

_ _ 

205-C3 205-C3S 

Cure oven, , natural gas-fired, Eclipse AH520 

Burner and 

evaporator rated 

at 5.5 

MMBTU/hr 

_ _ 

206-C1 206-C1S 

Heat cleaning oven, propane-fired, Steelman Model 4.56.54 BA-C 

0.6 MMBTU/hr 

Direct Flame 

Afterburner, 99.0% 

design control 

efficiency 

206-C1C V

205-PDR _ 

Nordson Powder Booth, powder coating booth 

2,160 lbs/hour _ _ 

Painting Operations/Group P-X15

274-E13 274-S13 

Plate Preparation & Inspection, paint booth 

_ 

Dry filter (paper), 90% design control efficiency 

274-C13 P

275-E4 and 275-

E6 

275-S4 and 275-

S6, resp. 

Shape Preparation, paint booths (two) _ 

Dry filter (paper), 90% design control efficiency 

275-C4 and 275-

C6, resp. P
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

1746-E4 1746-S4 

Plate Preparation & Inspection, paint booth 

_ 

Filter (paper), ESABHEBE, 90% design control efficiency 

1746-C4 P

60-E5 _ Engraving _ _ _ 

Painting Operations/Group P-FAC

P-FAC _ 

General facilitywide non-vessel brush, roller, spray and touch-up painting operationsmanual brush and spray painting 

_ _ _ 

103-E2 103-S2 Maintenance Shop, paint booth _ Filter (paper), 90% design control efficiency 103-C2 P

Specialty Shops 

64-E1 64-S1 

Electrical Shop drill 

press/sander (not 

used for wood) 

_ 

Baghouse, 95% 

design control 

efficiency 

64-C1 

64-E2 64-S2 Electrical Shop saw _ 

Baghouse, 95% 

design control 

efficiency 

64-C2 

64-E9 64-S9 Grinding metal _ Cyclone, 90% design control efficiency 64-C9 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

60-E2 60-S2 Grinding operations _ 

Cartridge filters 

Donaldson Torit 

Downflow DFO3-12, 

99% design control 

efficiency 

60-C2 

114-E1 114-S1 Saw metals _ 

Cartridge filters 

Donaldson Torit 

Downflow 2DF8, 

#40859, 99% design 

control efficiency 

114-C1 

4896-E1 4896-S1 

Melamine 

Operations (2 

Milling Machines, 

Band Saw, and 

Lathe) 

_ 

Dust collector, 

Donaldson Torit 

Model 90-219-5, 99% 

control efficiency 

4896-C1 

64-E3 64-S3 

Bayco burn-out 

oven, Model BB288, using propane, 

1979 

1 MMBTU/hr Afterburner, 1 MMBTU/hr 64-C3 

FAC-PW Building vents Facility-wide parts- washer operations _ _ _ 

Miscellaneous Activities 

FAC-BLST _ 

External abrasive 

blasting - facilitywide _ _ _ 

FAC-GRIT _ Utility grit off- loading _ _ _ 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

50-E1 50-S1 

Wheelabrator 

#11980 Table Blast 

Unit -Abrasive 

blasting/steel shots 

2.5 tons/hr 

Cartridge filters, Torit Ultraweb Downflow II DFT3-12, 99% design control efficiency 

50-C1 

17-E20 _ 

Abrasive blasting 

glove box/sand and 

glass, Vacublast 93-

2788 

_ _ _ 

4730-NR 

(Northside 

Reclaim) 

_ 

Torit Ultraweb 

Cartridge Dust 

collector, 99.0% 

design control 

efficiency 

4730-NRC 

4730-NB 

4730-NLE 

(Northside Local 

Exhaust) 

Abrasive 

blasting/steel shot - 

North Blast Room 

_ 

Torit Ultraweb 

Cartridge Dust 

collector, 99.0% 

design control 

efficiency 

4730-NLC 

4730-SR 

(Southside 

Reclaim) 

_ 

Torit Ultraweb 

Cartridge Dust 

collector, 99.0% 

design control 

4730-SRC 

4730-SB 

4730-SLE 

(Southside Local 

Exhaust) 

Abrasive 

blasting/steel shot - 

South Blast Room 

_ 

Torit Ultraweb 

Cartridge Dust 

collector, 99.0% 

design control 

efficiency 

4730-SLC 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

201-E1 201-S1 

Abrasive 

blasting/steel shot 

(10/1970), 

Wheelabrator #7614 

2.5 tons/hr 

Cartridge filters Torit 

UltraWeb Downflow 

DFO3-12, 99% 

design control 

efficiency 

201-C1 

Port-E1 Port-S1 Abrasive blasting/steel shot _ 

Baghouse, Standard 

Havens 12SH Alpha 

Mark III, 95.0% 

design control 

efficiency 

Port-C1 

Port-E2 through 

Port E-3 

Port-S2 through 

Port-S3 

Abrasive 

blasting/utility grit _ 

Baghouse, Torrit 

Model MTD-48-LD, 

95.0% design control 

efficiency 

Port-C2 through 

Port-C3 

Port-E4 through 

Port E-24 

Port-S4 through 

Port-S24 

Abrasive 

blasting/utility grit _ 

Baghouses (21 units), 

Vaculblast Co. Model 

D6 or D6S-8W, 

95.0% design control 

efficiency, each 

Port-C4 through 

Port-C24 

Port-E25 Port-S25 Abrasive blasting/utility grit _ 

Baghouse, 

MISCO/IPEC 

custom-made unit, 

95.0% design control 

efficiency 

Port-C25 

Port-E26 through 

Port-E31 

Port-S26 through 

Port-S31 

Abrasive 

blasting/utility grit _ 

Baghouses (6 units), 

MISCO/IPEC 

custom-made units, 

95.0% design control 

efficiency, each 

Port-C26 through 

Port-C31 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

4701-E1 4701-S1 

Abrasive 

blasting/steel grit, 

garnet, aluminum 

oxide 

384 lbs/hr 

Baghouse, 

MISCO/IPEC 

custom-made units, 

95 % design control 

efficiency 

4701-C1 

1768-E1 1768-S1 

Grinding/cutting/wel

ding - Welding 

School 

_ 

Cyclone, Torit, 

90 % design control 

efficiency 

1768-C1 

FAC-WELD _ Welding- facility- wide _ _ _ 

250-E1 250-S1 Welding/lead caulking operations _ 

Fabric filter, Portable 

Hawley TRAV-L vent 

fabric filter with 

HEPA filter dust 

collector, 95 % design 

control efficiency 

250-C1 

263-E1 263-S1 Welding operations _ 

Fabric filter, Portable 

Hawley TRAV-L vent 

fabric filter with 

HEPA filter dust 

collector, 95.0% 

design control 

efficiency 

263-C1 

4677-E1 4677-S1 Welding operations _ 

Baghouse, 95.0% 

design control 

efficiency 

4677-C1 

250-E2 250-S2 Arc gouger operations _ 

Fabric filter, Portable 

Hawley TRAV-L vent 

fabric filter with 

HEPA filter dust 

collector, 95.0% 

design control 

efficiency 

250-C2 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

FAC-GLUE _ Gluing operations- facility-wide _ _ _ 

ALC-E1 _ 

Abrasive blasting 

using ALC portable 

blasting machine, 

Model F-600R, 

2006 

800 lbs/hr _ _ 

501-E5 501-S5 Asbestos cutting NA Low efficiency cyclone 501-C5 

75-E5 75-S5 

Asbestos & nonasbestos cutting of 

gaskets 

NA 

Dust Collector work 

bench, Torit Model 

DD or Model 130, 

design control 

efficiency unknown 

75-C5 

74-E1 74-S1 Polyethylene cutting NA 

Baghouse, 95.0% 

design control 

efficiency 

74-C1 

FAC-SOLV _ Solvent/thinner usage- facility-wide _ _ _ 

175-E1 _ Fiberglass operations _ _ _ 

SS-E1 through 

SSE2 _ 

Service stations - 

gasoline _ _ _ 

5-E2 5-S2 

Wheelabrator 

/Tumblast Machine 

(Blast Unit)- 

Abrasive Blasting 

/steel shots 

2.5 tons/hr 

Baghouse, Wheelabrator Dustube Model 112-AC, 95.0% design control efficiency 

5-C2 
Northrop Grum

Perm

Effec

Emission Unit ID Stack ID Emission Unit Description Size/Rated Capacity* Pollution Control Device (PCD) Description PCD ID Pollu

Contr

205-B1 205-S1 Powder coating steel shot blast unit _ 

Baghouse, 

Wheelabrator USF 

44, design control 

efficiency 95% 

205-BC1 

205-B2 205-S2 Powder coating steel shot blast unit _ 

Baghouse, Pangborn 

Model 25-5-8, Type 

HP-1, design control 

efficiency 95% 

205-BC2 

Site Remediation 

Activities - - - - - 

*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 

SO2 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 

SO2 SO2 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 5-40-900 
Northrop 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 

SO2 SO2 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 5-50-80 
Northrop 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 106

 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, and 78-E3) combined shall consume no more 

than 14.85 x 106 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 may 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 content 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 content per shipment. These records shall be maintained 

at the facility for inspection by DEQ 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 burning distillate oil with a maximum sulfur content of 

0.05% which more than qualifies as a “very low 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 and 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 specifications 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 certification from the fuel supplier 

with each shipment of distillate oil. These certifications meet the requirements of 40 

CFR 60.49b(r). Each fuel supplier certification 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 complies with the American Society for Testing 

and Materials specifications D396 for 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 familiarization 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 NO2) (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 credible 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, III.C.3, and III.D.1, and Table III.A. 

Initial compliance with the lbs/MMBTU NOx limit shall be determined by 

performance testing as specified in 40 CFR 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 NOx limit shall be determined as specified in 

Condition III.B.4. Compliance to the NOx annual emission limit shall be determined 

by using the actual emission factor from performance 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 for additional requirements not included in 

this permit. 

(9 VAC 5-80-110, and Condition 14 of 6/04/07 NSR permit) 

B. Monitoring 

1. SO2 and PM-10 Emissions Monitoring- Emissions of SO2 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 SO2 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 SO2 and PM-10 emissions in pounds per million 

BTU using maximum fuel throughput, fuel sulfur content, and appropriate emission 

factors from AP-42, 5th Edition. The permittee shall maintain records of daily 

calculations for the most recent 5-year period. If the one-time maximum emission 

demonstration option is chosen, the permittee shall maintain a record of such a 
Northrop 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 the 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 visible 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 minutes 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 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 duration of any visible emission incident, and any corrective action to 

 eliminate visible emissions. 

 If a VEE is conducted, records shall be in accordance with Method 9 (40 CFR 60, 

Appendix A). 

(9 VAC 5-80-110) 

4. Continuous Emissions Monitoring Systems (CEMS)- The permittee shall install, 

calibrate, maintain, and operate a continuous 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 continuous 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 followed for installation, evaluation, and 

operation of the continuous monitoring system. The span value for nitrogen oxides 

shall be set at 500 ppm. The 1-hour average 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 calculated using the data points required under 40 
Northrop 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 systems, 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 during 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 maintenance shall be performed on the boiler to 

eliminate the visible emissions. If visible emissions continue after maintenance 

actions, a visible emissions evaluation (VEE) shall be immediately 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 percent (10%), the VEE shall 

continue for one hour from initiation to determine 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 emission incident, and any corrective action to eliminate 

visible emissions. 

If a VEE is conducted, records 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 all No. 6 fuel oil shipments purchased, 

indicating sulfur content per shipment, and 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 maintained 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 all required visible emissions 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 emission 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 and/or observations records and monthly 

emissions calculations shall be maintained at the facility for inspection by DEQ for 
Northrop Grumman Shipbuilding, Inc. 

Permit Number: TRO-60153 

Effective Date: June 1, 2009 

Page 32 

the most recent 5-year period. If a one-time 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 emission 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 shall be arranged with the Tidewater Regional 

Office. These records shall include, but are not limited to: 

a. Daily and annual throughput of distillate 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 Tidewater Regional Office to verify 

compliance with the tons/year emission limitations. 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 meets 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 observations and visible emission evaluations. 

f. Records of initial compliance performance 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 constructed so as to allow for emissions testing 

upon reasonable notice at any time, using appropriate methods. Sampling ports shall 

be provided when requested at the appropriate 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 the 30-day average emission rate shall be 

used to determine compliance with the lbs/MMBTU NOx emission limitation. The 

30-day average emission rate shall be calculated 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 compliance with the lbs/MMBTU NOx limitation 

through the use of a 30-day performance 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 initial performance test specified in Condition 

III.D.1 and the performance evaluation of the CEMS using the applicable 

performance specifications found in Appendix 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 emissions from the boilers. If there are no 

excess emissions during the calendar quarter, the permittee shall submit a report 

semi-annually stating that no excess emissions occurred during the semi-annual 

reporting period. Excess emissions are defined as any calculated 30-day rolling 

average NOx emission rate as determined by Condition III.B.4 which exceeds the 

lbs/MMBTU NOx emission limitation in Condition III.A.13. The permittee shall also 

submit a NOx emission quarterly report containing 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 calendar quarter. All semi-annual reports 

specified in this condition shall be postmarked 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 Office within 30 days after the end of each 

semi-annual period. If no shipments of distillate oil were received during the semiannual period, the semi-annual report shall consist 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 received during the semi-annual period, 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 semi-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 operator of the facility that the fuel supplier 

certifications or summaries of fuel supplier 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 address 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 5-40-2410 
Northrop 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 visible 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 controlled by a cartridge filter system (Unit 

Ref. No. 550-C1a). The cartridge 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 controlled by a cartridge filter system 

(Unit Ref. No. 550-C1a). The cartridge filter system shall be provided with adequate 

access for inspection and shall be in operation when the furnace(s) is operating. 

(9 VAC 5-80-110 and 40 CFR 63.7690(c)) 

4. Emission Control- Particulate emissions from the foundry operation Units Ref. No. 

555-E1 and 555-E11 shall be controlled by fabric filters (Unit Ref. No. 555-C1 and 

555-C11, respectively). The fabric filters shall be provided with adequate access for 

inspection and shall be in operation 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 continuously measure the differential pressure drop 

across the 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, 40 CFR 64.2, and 40 CFR 63 Subpart EEEEE) 

2. Monitoring Device- The cartridge filter system (Unit 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 shall be provided with adequate access for 

inspection and shall be in operation when 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 hours of operation utilizing EPA Method 9 

(reference 40 CFR 60, Appendix A). The permittee 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 daylight hours of operations for visible 

emissions for at least six minutes. If visible emissions are noted from the stack, 

operational adjustment or maintenance shall be performed to eliminate the visible 

emissions. If visible emissions continue after maintenance actions, a visible 

emissions evaluation (VEE) shall be immediately 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 percent (10%), the VEE shall continue for 

one hour from initiation to determine 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 emission incident, and any corrective action to eliminate 

visible emissions. 

If a VEE is conducted, records 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. 550-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: Pressure 

DropPressure 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 Reclaim 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 Reclaim 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: Pressure 

DropPressure 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: Bag 

ConditionAnnual 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, including, but not limited to, maintaining 

necessary parts for routine repairs 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 required 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 intervals) at all times that 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) is operating. Data recorded during 

monitoring malfunctions, associated repairs, and required quality assurance or control 

activities shall not be used for purposes of compliance assurance monitoring, 

including data averages and calculations, or fulfilling a minimum data availability 

requirement, if applicable. The permittee shall 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 any sudden, infrequent, not reasonably 

preventable failure of the monitoring to provide valid data. Monitoring failures that 

are caused in part by inadequate maintenance 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) (including the control 

device and associated capture system) to its normal or usual manner of operation as 

expeditiously as practicable in accordance with good air pollution control practices 

for minimizing emissions. The response shall include minimizing the period of any 

startup, shutdown or malfunction and taking any necessary corrective actions to 

restore normal operation and prevent the likely recurrence of the cause of an 

excursion or exceedance (other than those caused by excused startup and shutdown 

conditions). Such actions may include initial 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 procedures and records, and 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 limitation or standard for which the approved 

monitoring did not provide an indication of an excursion or exceedance while 

providing valid data, or the results of compliance or performance testing document a 

need to modify the existing indicator ranges or designated conditions, the permittee 

shall promptly notify the Director, Tidewater Regional Office and, if necessary, 

submit a proposed modification to this permit to address the necessary monitoring 

changes. Such a modification may include, but is not limited to, reestablishing 

indicator ranges or designated conditions, 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 Reference 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 the results of the evaluation 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 correct 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 Operation 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 certification that the foundry purchases and uses only metal 

ingots, pig iron, slitter, or other materials that do not include post-consumer 

automotive body scrap, post-consumer engine blocks, post-consumer oil filters, oily 

turnings, lead components, mercury switches, 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 standards in 40 CFR 63.7700(b) within 30 calendar 

days after the compliance date specified 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 written 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 must contain elements described in 40 CFR 

63.7710 (b)(1) through (6). Applicable requirements 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, including a preventive 

maintenance schedule that is consistent with the manufacturer’s instructions for 

routine and long-term maintenance (40 CFR 63.7710 (b)(3)). 

c. A site specific monitoring plan for each bag leak detection system (40 CFR 

63.7710(b)(4)). 

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

e. Procedures for providing an ignition source to mold vents of sand mold systems 

in each pouring area and pouring station unless it has been determined that the 

mold vent gases either are not ignitable, ignite automatically, 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 the 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 must 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 manufacturer to be capable of detecting PM 

emissions at concentrations of 0.0044 grains per actual cubic foot or less. 

b. The bag leak detection system sensor must provide output of relative particulate 

matter loadings and continuously record the output with a data logger. 

c. The system must be equipped with an alarm that will sound when an increase in 

relative particulate loading is detected over the alarm set point established in the 

O&M Plan, and the alarm must be located 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 set points and the alarm delay time (if 

applicable) 

e. Following the initial adjustment, the sensitivity or range, averaging period, alarm 

set point, or alarm delay time should not be adjusted without the approval of the 

Director, Tidewater Regional Office. Except, once per quarter, the sensitivity of 

the bag leak detection system may be adjusted to account for seasonal effects 

including temperature and humidity according 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, the 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 all emission data and operating parameters 

necessary to demonstrate compliance with this permit. The content and format of 

such records shall be arranged with the Director, Tidewater Regional Office. These 

records shall include, but are not limited to: 

a. Pressure drop monitoring records. 

b. Visible emission observations, and if VEE 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 for 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)(iii) through (v) related 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, the corrective action 

taken, and the date on which corrective action was completed (40 CFR 

63.7743(c)(2)). 

j. Records of all inspections and maintenance of the cartridge filter system as 

required by 40 CFR 63.7740(c), including all information needed to document 

conformance with these requirements (40 CFR 63.7743(c)(1)). 

k. Records that document continuous compliance 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, preventive maintenance, site-specific bag leak 

detection system monitoring, 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, monitor performance data, corrective actions 

taken, any written quality improvement plan (QIP) required pursuant to §64.8 and any 

activities undertaken to implement a quality improvement plan (QIP), and other 

supporting information required to be maintained under this part (such as data used to 

document the adequacy of monitoring, or records of monitoring 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 compliance date specified in 40 CFR 63.7683 (April 

23, 2007) to demonstrate initial compliance with 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 arc 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 compliance 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 considered timely if conducted anytime within the 

sixth calendar month following the month 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 40 
Northrop 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 concurrently 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 exhaust stream, determined according to 40 

CFR 63.7732(b), did not exceed 0.005 grains/dscf, and 
Northrop 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 emissions 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 average 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 materials that do not 

include post-consumer automotive body scrap, post-consumer engine blocks, postconsumer oil filters, oily turnings, 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 approval 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 requirements 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 appropriate 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 Requirements (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 tests post-marked at least 60 calendar days 

prior to such date (40 CFR 63.7750(d)). 

d. Notification of compliance status post-marked 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-marked 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 Reports (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 January 1 through June 30, respectively. The 

reports shall include information 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 downtime incidents (other than downtime 

associated with zero and span or other daily calibration checks, if applicable); and 

c. A description of the actions taken to implement a quality improvement plan (QIP) 

during the reporting period as specified in §64.8. Upon completion of a QIP, the 

owner or operator shall include in the next summary report documentation that the 

implementation of the plan has been completed 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 5-40-260 
Northrop 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 visible 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 the 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 all emission data and operating parameters 

necessary to demonstrate compliance with this permit. The content and format of 

such records shall be arranged with the Director, Tidewater Regional Office. These 

records shall include, but are not limited to: 

a. Annual throughput of abrasive blast media (in tons) and hours of operation for 

each of the Steel Preparation and Fabrication Operations activities listed in Table 
Northrop Grumman Shipbuilding, Inc. 

Permit Number: TRO-60153 

Effective Date: June 1, 2009 

Page 52 

V.A. The abrasive blast media throughput (in tons) and hours of operation shall 

be recorded and maintained in a logbook for each calendar month such that the 

annual amounts can be calculated monthly as the sum of each consecutive 12-

month period. 

b. Visible emission evaluations (VEE) records 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. The 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 year, 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 maintenance of the air pollution control 

equipment. Operators shall be trained and certified in the proper operation of all such 

equipment. The permittee shall have available good written operating procedures and 

a maintenance schedule for all such equipment. 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 record the monthly throughput of lead in a 

logbook to be maintained at the facility for 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 week (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 adjustment or maintenance shall be performed to 

eliminate the visible emissions. If visible emissions continue after maintenance 

actions, a visible emissions evaluation (VEE) shall be immediately 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 percent (10%), the VEE shall 

continue for one hour from initiation to determine 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 emission incident, and any corrective action to eliminate 

visible emissions. 

If a VEE is conducted, records 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 all emission data and operating parameters 

necessary to demonstrate compliance with this permit. The content and format of 

such records shall be arranged with the Director, 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 consecutive twelve (12) month period. 

b. Operator training and certification records. 

c. Pollution control equipment maintenance records. 

d. Weekly visible emissions observations, visible emissions 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/Planer/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 Operations shall not exceed the 

limitations specified in Table VII.A. Compliance 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 Woodworking Operations shall be 

controlled by the use of cyclones. The cyclones shall be provided with adequate 

access for inspection and shall be in operation 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 operation for visible emissions. Lack of 

visible emissions shall indicate compliance with the provisions 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 absence of visible emissions, and 

Any corrective action to eliminate visible emissions. 

(9 VAC 5-80-110) 

2. The permittee shall inspect the cyclones once per month for structural integrity and 

record the results in a logbook. 

(9 VAC 5-80-110) 

C. Recordkeeping 

1. The permittee shall maintain records of all emission data and operating parameters 

necessary to demonstrate compliance with this permit. The content and format of 

such records shall be arranged with the Director, 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 Operations 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 with adequate access for inspection 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 carried out as required by 40 CFR 63.342(f), 

including the Operation and Maintenance 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 Operations are subject to the provisions of 40 

CFR 63 Subpart N - National Emission Standards for Chromium Emissions from 

Hard and Decorative Chromium Electroplating 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 drainage, no chromic acid buildup on the packed 

beds, and no evidence of chemical attack on the structural integrity of the device. 

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)) 

2. The permittee shall visually inspect the back portion of the mist eliminator of the 

packed scrubber (4620-C1) once per 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 packed 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 makeup 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 velocity pressure at the inlet to the packed 

scrubber and pressure drop across the scrubber 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 indicated compliance in initial compliance tests 

for the packed scrubber. The permittee shall maintain a record of the initial 

compliance test at the facility for inspection 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 (decorative chromium or hard chromium) 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 all emission data and operating parameters 

necessary to demonstrate compliance with this permit. The content and format of 

such records shall be arranged with the Director, Tidewater Regional Office. These 

records shall include, but are not limited to: 

a. Quarterly inspections of the packed scrubber (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: Records 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 defined in 40 CFR 63.341. This record shall 

be kept for the life of the chromium 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 electroplating facility. The report shall cover the 

time period including the previous six-month 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 parameter(s) that is monitored for compliance 

determination, as required by 40 CFR 63.343(c); 

c. The relevant emission limitation for the affected source, and the operating 

parameter value, or range of values, that correspond to compliance with this 

emission limitation as specified in the notification of compliance status required 

by 40 CFR 63.347(e); 

d. The beginning and ending dates of the reporting period; 

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

f. The total operating time of the affected 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 breakdown of the total duration of excess 

emissions during the reporting period into those that are due to process upsets, 

control equipment malfunctions, other 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 reasons 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 controls since the last 

reporting period; 

k. The name, title, and signature of the responsible official who is certifying the 

accuracy of the report; and 
Northrop 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 for 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 grams 

VOHAP 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 Painting 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 shall cause or allow the application of any 

coating to a ship with an as-applied VOHAP 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) through (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 alternative test method capable of measuring 

independent VOHAP shall be used to determine 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. Note: 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 additional requirements not included in this 

permit. 

(9 VAC 5-80-110, and 40 CFR 63 Subpart II) 

4. Emission Controls- VOC emissions from the powder 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 the 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 parts 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 coatings 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 LimitThe throughput of natural gas for the parts-washer burners, preheat oven, and cure 

oven (Units 205-C1a through c, 205-C2, and 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) combined shall not exceed the limits 

specified below: 

 

Particulate Matter 0.5 tons/year 

Nitrogen Oxides 6.6 tons/year 

 (as NO2) 

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 stated 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 coating that is received by the 

facility, the permittee shall determine the coating category, the applicable VOHAP 

limit as specified in 40 CFR 63.783(a), and certify 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 violation. If the permittee performs the 

certification testing, only one of the containers 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 compliance 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 permittee 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 demonstration conducted by the permittee or any 

regulatory agency using Method 24 shall take 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 VOHAP 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 that all handling and transfer 

of VOC-containing marine coating materials to and from containers, tanks, vats, 

drums, and piping systems is conducted in a manner that minimizes spills. The 

permittee shall inspect all containers, tanks, 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 systems housing VOC-containing marine coating 

materials shall remain closed unless materials 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 such 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, their 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 meet the standards as described in 40 CFR 

63.783(b)(2); 

g. The results of any Method 24 (as referenced 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 procedures which shall include, as a 

minimum, the manufacturer's written requirements or recommendations. The 

monitoring device shall be provided 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 permittee 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 operation (Units 205-C1a through c, 205-C2, 205-C3, and 206-

C1) at least once per month when in operation for visible 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. Records of observations 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 per 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 calendar 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 maintained 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 coating operation (205-PDR) 

as necessary to demonstrate compliance with this permit. The content and format of 

such records shall be arranged with the Director, 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 monthly 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 purchase records shall be maintained for the most recent 

12-month period indicating at minimum the 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 sum 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 visible 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 described 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 based 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 completion 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, Tidewater 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), except 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 detected, 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=4.10P0.67 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=4.10P0.67 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=4.10P0.67 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=4.10P0.67 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=4.10P0.67 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=4.10P0.67 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 Permit 
Northrop 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 emissions 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 afterburner 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 remove, destroy, or prevent the discharge 

into the atmosphere of at least 85% by weight of volatile organic compound 

emissions. Achievement of the VOC emission standard shall be achieved by 

complying with the applicable control requirements 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 reclamation (either by outside services or 

in-house) or by incineration. Disposal records shall be maintained 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 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 minutes 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 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 duration of any visible emission incident, and any corrective action to 

 eliminate visible emissions. 

 If a VEE is conducted, records 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 washer 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. Volatile organic compounds shall not be 

intentionally spilled, discarded in sewers which are not connected to a treatment 

plant, or stored in open containers or handled in any other manner that would result in 

evaporation beyond that consistent with air 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 all emission data and operating parameters 

necessary to demonstrate compliance with this permit. The content and format of 

such records shall be arranged with the Director, 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 inspections 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 P0.67 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 Permit 
Northrop 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 P0.67 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 the arc-gouging process (Unit Ref. 

No. 250-E2) shall be controlled by a dust collector. 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 per year, calculated monthly 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 adequate 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 Activities 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 across 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 per month when the unit is in operation 

during daylight hours of operation for at least eighteen minutes in accordance with 

EPA Method 9 (reference 40 CFR 60, Appendix A). If any visible emissions are 

noted, corrective action shall be taken to eliminate 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 visible 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 emissions for at least 6 minutes. If visible 

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 minutes 

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 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 duration of any visible emission incident, and any corrective action to 

 eliminate visible emissions. 

 If a VEE is conducted, records 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 Subpart GGGGG that is 

contained in the remediation material excavated, extracted, pumped, or otherwise 

removed during all of the site remediations conducted 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 all emission data and operating parameters 

necessary to demonstrate compliance with this permit. The content and format of 

such records shall be arranged with the Director, Tidewater Regional Office. These 

records shall include, but are not limited to: 

a. The annual throughput of stainless steel catapult plates for the arc gouger in linear 

feet, calculated monthly as the sum of each consecutive 12-month period. 

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

c. Records of visible emission evaluations of the arc gouger (250-E2) using EPA 

Method 9 (reference 40 CFR 60, Appendix A) and any corrective action. 

d. Records of visible emissions observations, any corrective action, and visible 

emission evaluations using EPA Method 9 (reference 40 CFR 60, Appendix A), if 

performed, for Miscellaneous Activities units other than the arc gouger (250-E2). 

e. Records of written documentation to support the determination that the total HAP 

quantity in the remediation materials is less than 1 megagram per year from all 

remediation activities at your facility 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 description 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 Hp 
Northrop 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 Hp 
Northrop 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/hr 
Northrop 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/hr 
Northrop 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

NA 
Northrop 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 H2SO4 NA 

161-PT Four Pickling Tanks, each 

3,240 gal 9 VAC 5-80-720 B H2SO4 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/hr 
Northrop 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 NA 
Northrop 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 NA 
Northrop 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 H2O2 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 NH4OH 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 NA 
Northrop 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 PO4 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 compliance with all requirements of the federal 

Clean Air Act as may apply. Based on this presumption, no monitoring, recordkeeping, or 

reporting shall be required for these emission 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 permit 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 applicable 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 Standards 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 shall alter the provisions of §303 of the federal Clean Air Act, 

including the authority of the administrator under that section, the liability of the owner for 

any violation of applicable requirements prior to or at the time of permit issuance, or the 

ability to obtain information by the administrator pursuant to §114 of the federal Clean Air 

Act, (ii) the Board pursuant to §10.1-1314 or §10.1-1315 of the Virginia Air Pollution 

Control Law or (iii) the Department pursuant 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 administrator and citizens 

under the federal Clean Air Act, except those that have been designated as only stateenforceable. 

(9 VAC 5-80-110 N) 

B. Permit Expiration 

This permit has a fixed term of five years. The 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 VAC 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 the 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 action on the application under 9 VAC 5-80-

150. 

3. No source shall operate after the time that 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 complete 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 the 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 completeness determination made pursuant 

section 9 VAC 5-80-80 D, the applicant fails 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 maintained 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 existing at the time of sampling or measurement. 

(9 VAC 5-80-110 F) 

2. Records of all monitoring data and support information shall be retained for at least 

five years from the date of the monitoring sample, measurement, report, or 

application. Support information includes all calibration and maintenance records 

and all original strip-chart recordings for continuous monitoring 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 operating parameter requirements, as 

documented by continuous emission monitoring, periodic monitoring, or 

Compliance Assurance Monitoring (CAM) which indicates an exceedance 

of emission limitations or operational restrictions; or, 

(3) Failure to meet monitoring, recordkeeping, 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 this semi-annual reporting period.” 

(9 VAC 5-80-110 F) 

D. Annual Compliance Certification 

Exclusive of any reporting required to assure compliance with the terms 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 and conditions of this permit including emission limitation 

standards or work practices. The compliance certification 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, consistent with 9 VAC 5-

80-80 G, and shall include: 

1. The time period included in the certification. 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 intermittent, 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 source 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 certification 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, Tidewater Regional Office within four daytime 

business hours after discovery of any deviations from permit requirements which may cause 
Northrop Grumman Shipbuilding, Inc. 

Permit Number: TRO-60153 

Effective Date: June 1, 2009 

Page 91 

excess emissions for more than one hour, including 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 explaining the problem, any corrective actions or 

preventative measures taken, and the estimated 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 compliance 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 pollution 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 later than four daytime business hours after the 

malfunction is discovered, notify the Director, Tidewater Regional Office by facsimile 

transmission, telephone or telegraph of such failure or malfunction 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 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. 

When the condition causing the failure or malfunction has been corrected and the equipment 

is again in operation, the owner shall notify the Director, Tidewater Regional Office. 

1. The emission units that have continuous monitors 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 reporting and the procedure requirements 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), Sand 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 applicable 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 30th day 

following the end of each calendar quarter, and all semi-annual reports shall be 

postmarked by the 30th day following the end of each calendar semi-annual period 

(June 30th and January 30th). 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 the source. The nature and cause of any 

malfunction (if known), the corrective action 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 adjusted, such information shall be stated in 

the report. 

All malfunctions of emission units not subject to 9 VAC 5-40-50 C and 9 VAC 5-50-

50 C require written reports within 14 days of the discovery 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 any condition, requirement or portion of the permit 

is held invalid or inapplicable under any circumstance, such invalidity 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 and conditions of this permit. Any permit 

noncompliance constitutes a violation of the federal Clean Air 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 Regulations 9 VAC 5-80-50, 9 VAC 5-80-1100, 9 VAC 5-

80-1605, or 9 VAC 5-80-2000 and may require a permit modification and/or revisions except 

as may be authorized in any approved 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 terminating 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 shall 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 consistent with the requirements of 9 VAC 5-80-310 

through 9 VAC 5-80-350. The actual emissions covered 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, structure, facility, or 

installation, no owner or other person shall cause or permit any materials or property to be 

handled, transported, stored, used, constructed, altered, repaired, or demolished without 

taking reasonable precautions to prevent particulate matter from becoming airborne. Such 

reasonable precautions may include, but are not limited to, the following: 

1. Use, where possible, of water or chemicals for control of dust in the demolition of 

existing buildings or structures, construction operations, the grading of roads, or the 

clearing of land; 

2. Application of asphalt, water, or suitable chemicals on dirt roads, materials 

stockpiles, and other surfaces which may create 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 containment methods shall be employed during 

sandblasting or similar operations; 

4. Open equipment for conveying or transporting material likely to create objectionable 

air pollution when airborne shall be covered or treated in an equally effective manner 

at all times when in motion; and, 

5. The prompt removal of spilled or tracked dirt 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 blowing, and malfunction, 

owners shall, to the extent practicable, maintain and operate any affected facility including 

associated air pollution control equipment in a manner consistent with air pollution control 

practices for minimizing emissions. Determination of whether acceptable operating and 

maintenance procedures are being used will be based on information available to the Board, 

which may include, but is not limited to, monitoring 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 operating. 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 scenario 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 substances or parameters for the purpose of 

assuring compliance with the permit 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 months after promulgation of the applicable 

requirement. No such reopening is required if the 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 that inaccurate statements were made in 

establishing the emissions standards 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 assure compliance with the applicable 

requirements. 

3. The permit shall not be reopened by the Board if additional applicable state 

requirements become applicable to a major 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 permittee shall maintain the permit on 

the premises for which the permit has been issued 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 stationary 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 affirmative defense to an action brought for 

noncompliance with technology-based emission 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 operating logs, or other relevant evidence 

that show the following: 

a. A malfunction occurred and the permittee can 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 include a description of the malfunction, any 

steps taken to mitigate emissions, and corrective actions taken. The notification 

may be delivered either orally or in writing. The notification may be delivered by 

electronic mail, facsimile transmission, telephone, or any other method that 

allows the permittee to comply with the deadline. This notification fulfills the 

requirements of 9 VAC 5-80-110 F.2.b to report 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 addition 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 application or any amendments thereto or if the 

permittee violates, fails, neglects or refuses to comply with the terms 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 facts 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 complete 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 Class I or II substances subject to a standard 

promulgated under or established by Title VI (Stratospheric 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 requirements of National Emissions Standards for 

Hazardous Air Pollutants (40 CFR 61) Subpart M, National Emission Standards for Asbestos 

as it applies to the following: Standards for Demolition and Renovation (40 CFR 61.145), 

Standards for Insulating Materials (40 CFR 61.148), 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 any federally approved economic incentives, 

marketable permits, emissions trading and other 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 decreases 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 decreases 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 increases and decreases in emissions. 

3. The owner shall meet all applicable requirements 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 required under the federal Clean Air Act or under 

any of its applicable federal requirements, 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 Standards for Odor in 9 VAC 5-40-130 et seq. 

(Rule 4-2), and the Standards of Performance for Odorous Emissions in 9 VAC 5-50-

130 et seq. (Rule 5-2). 

2. The facility is subject to the Emission Standards for Toxics Pollutants from Existing 

Sources in 9 VAC 5-60-200 et seq. (Rule 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)