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Statement of Legal and Factual Basis

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					                                    COMMONWEALTH OF VIRGINIA
                                   Department of Environmental Quality
                                        Tidewater Regional Office

                             STATEMENT OF LEGAL AND FACTUAL BASIS

                                    Northrop Grumman Shipbuilding, Inc.
                                          4101 Washington Avenue
                                       Newport News, Virginia 23607
                                        Permit Number: TRO-60153

Title V of the 1990 Clean Air Act Amendments required each state to develop a permit program to ensure that
certain facilities have federal Air Pollution Operating Permits, called Title V Operating Permits. As required by
40 CFR Part 70 and 9 VAC 5 Chapter 80, Northrop Grumman Shipbuilding has applied for a Title V Operating
Permit for its Newport News, Virginia facility. The Department has reviewed the application and has
prepared a draft Title V Operating Permit.




Engineer/Permit Contact:                                                    Date:      June 1, 2009




Air Permit Manager:                                                         Date:      June 1, 2009



Regional Director:                                                          Date:      June 1, 2009
                                                                                           Northrop Grumman Shipbuilding, Inc.
                                                                                                                    TRO-60153
                                                                                            Statement of Legal and Factual Basis
                                                                                                                   June 1, 2009
                                                                                                                         Page 2


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

County-Plant Identification Number: 51-700-00013


II. SOURCE DESCRIPTION
NAICS Code: 336611- Shipbuilding and repair.
Northrop Grumman Shipbuilding (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 or repaired 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
firing propane or No. 2 fuel oil which belong in the Steel Preparation and Fabrication Operation, the 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
                                                                                           Northrop Grumman Shipbuilding, Inc.
                                                                                                                    TRO-60153
                                                                                            Statement of Legal and Factual Basis
                                                                                                                   June 1, 2009
                                                                                                                         Page 3

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
a baghouse. 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. Emissions
are primarily particulate matter, some VOCs and combustion by-products from ovens/furnaces.

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 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 three process
lines contained within the building (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 three locations. Building No. 3 primarily makes pallets, boxes, and shoring timbers. Equipment used includes
moulders, 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. Full-scale 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 II- National 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 semi-portable 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
                                                                                            Northrop Grumman Shipbuilding, Inc.
                                                                                                                     TRO-60153
                                                                                             Statement of Legal and Factual Basis
                                                                                                                    June 1, 2009
                                                                                                                          Page 4

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 then amended on 2/14/2001.

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,
welding/brazing, gluing, solvent usage, ship mock-ups, wastewater treatment, asbestos handling, shipboard foam installation
applications, vessel cleaning, radionuclides, general plant activities (painting, welding, sandblasting, general carpentry, parts
cleaning, vehicle maintenance, offset printing, blueprinting, copying, and firefighting), two gasoline service stations, and
research and development activities. Emission units that do not qualify as insignificant activities are addressed.

Also addressed here are the remediation activities which are mainly 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 qualify as insignificant activities.

The facility is a Title V major source of PM-10, NOx, SO2 , VOC, and HAPs. This source is located in an attainment area for
all pollutants, and is a PSD major source. The facility was started before 1972; hence many of the combustion equipment and
process units do not have NSR permits. Nevertheless, the facility is currently permitted under several Minor NSR permits as
listed below.
                                                                                        Northrop Grumman Shipbuilding, Inc.
                                                                                                                 TRO-60153
                                                                                         Statement of Legal and Factual Basis
                                                                                                                June 1, 2009
                                                                                                                      Page 5




Minor NSR Permit Date                Permitted Equipment- Process         Comment

2/24/78                              Argon/Oxygen Degassing (AOD)
                                     Furnace- Foundry Operations
10/18/79                             Bayco Model BB Burn-out Oven-
                                     Specialty Shops
12/16/81                             Lead foundry- Secondary Lead
                                     Processing
1/30/85                              Two barge mounted boilers- Fuel
                                     Burning Equipment
2/12/86                              Aluminum flame spray facility-
                                     Painting Operations
9/02/94                              Arc-gouger equipment-
                                     Miscellaneous Activities
2/14/2001                            Powder coating- Painting             Superseded 7/10/2000 NSR
                                     Operations
6/04/2007                            Two distillate oil-fired boilers-    Superseded 4/24/2006 NSR
                                     Fuel Burning Equipment


III.      COMPLIANCE STATUS
A full compliance evaluation of this facility, including a site visit, was conducted on September 25, 2007. In addition, all
reports and other data required by permit conditions or regulations, which are submitted to DEQ, are evaluated for compliance.
 Based on these compliance evaluations, the facility has not been found to be in violation of any state or federal applicable
requirements at this time.
                                                                                                                 Northrop Grumman Shipbuilding, Inc.
                                                                                                                                          TRO-60153
                                                                                                                  Statement of Legal and Factual Basis
                                                                                                                                         June 1, 2009
                                                                                                                                               Page 6


IV.     EMISSION UNIT AND CONTROL DEVICE IDENTIFICATION
The emissions units at this facility consist of the following:

                                                                                Pollution Control
                                    Emission Unit                Size/Rated                                             Pollutant
Emission Unit ID    Stack ID                                                    Device (PCD)        PCD ID                              Applicable Permit Date
                                    Description                  Capacity*                                              Controlled
                                                                                Description
Fuel Burning Equipment/ Steam Boilers

                                       No. 6 fuel oil-fired
                                     barge- mounted boiler,
                                                                    213.26
    FTSF-E1            FTSF-S1           Combustion                                      _                   _                _            1/13/85 NSR permit
                                                                   MMBTU/hr
                                      Engineering Model
                                        V2M-8, pre-1983
                                       No. 6 fuel oil-fired
                                     barge- mounted boiler,
                                                                    213.26
    FTSF-E2            FTSF-S2           Combustion                                      _                   _                _            1/13/85 NSR permit
                                                                   MMBTU/hr
                                      Engineering Model
                                        V2M-8, pre-1983
                                         No. 6 fuel oil or
                                       recovered oil-fired
      78-E1             78-S1                                    135 MMBTU/hr            _                   _                _            1/13/85 NSR permit
                                      boiler, B&W Integral
                                          Furnace, 1948
                                         No. 6 fuel oil or
                                       recovered oil-fired
      78-E2             78-S1                                    135 MMBTU/hr            _                   _                _            1/13/85 NSR permit
                                      boiler, B&W Integral
                                          Furnace, 1948
                                                                                                               Northrop Grumman Shipbuilding, Inc.
                                                                                                                                        TRO-60153
                                                                                                                Statement of Legal and Factual Basis
                                                                                                                                       June 1, 2009
                                                                                                                                             Page 7

                                                                              Pollution Control
                                  Emission Unit              Size/Rated                                               Pollutant
Emission Unit ID   Stack ID                                                   Device (PCD)        PCD ID                              Applicable Permit Date
                                  Description                Capacity*                                                Controlled
                                                                              Description
                                       No. 6 fuel oil or
                                     recovered oil-fired
     78-E3             78-S1                                 135 MMBTU/hr              _                   _                _            1/13/85 NSR permit
                                    boiler, B&W Integral
                                        Furnace, 1948
                                       No. 2 fuel oil,
     TS-E1            TS-S1                                  245.3 MMBTU/hr     Low NOx Burner             _               NOx           6/04/07 NSR permit
                                     manufactured 1994
                                       No. 2 fuel oil,
     TS-E2            TS-S2                                  245.3 MMBTU/hr     Low NOx Burner             _               NOx           6/04/07 NSR permit
                                     manufactured 1997
Fuel Burning Equipment/ Steel Preparation and Fabrication

                                     Propane-fired oven,
     276-E1           276-S1          construction date      15.3 MMBTU/hr             _                   _                _                    _
                                         unknown
                                     Propane-fired Ray
                                     Campbell Furnace,
     276-E2           276-S2                                 15.4 MMBTU/hr             _                   _                _                    _
                                     construction date
                                         unknown
Fuel Burning Equipment/ Foundry

                                      Propane-fired heat
     550-E8           550-S8                                 15.3 MMBTU/hr             _                   _                _                    _
                                   treating furnace # 5784
                                      Propane-fired heat
     550-E9           550-S9                                  27 MMBTU/hr              _                   _                _                    _
                                   treating furnace # 5302
                                      Propane-fired heat
    550-E13          550-S13                                  12 MMBTU/hr              _                   _                _                    _
                                   treating furnace #57531
                                                                                                               Northrop Grumman Shipbuilding, Inc.
                                                                                                                                        TRO-60153
                                                                                                                Statement of Legal and Factual Basis
                                                                                                                                       June 1, 2009
                                                                                                                                             Page 8

                                                                              Pollution Control
                                  Emission Unit              Size/Rated                                               Pollutant
Emission Unit ID   Stack ID                                                   Device (PCD)        PCD ID                              Applicable Permit Date
                                  Description                Capacity*                                                Controlled
                                                                              Description

Fuel Burning Equipment/ Miscellaneous Activities

                                  Annealing oven-
    1278-E1          1278-S1                                 20.79 MMBTU/hr            _                   _                _                    _
                                  Northside, #2 oil
                                  Generator, stationary,
    36-38152             _                                       672 HP                _                   _                _                    _
                                  Nancy Lee, diesel
    76-4179              _        Generator B905, diesel         672 HP                _                   _                _                    _
                                  Generator, portable,
    1-35058              _                                       740 HP                _                   _                _                    _
                                  diesel
                                  Generator, portable,
    2-35060              _                                       740 HP                _                   _                _                    _
                                  diesel
                                  Generator, portable
    60-40340             _                                       740 HP                _                   _                _                    _
                                  transfer car, diesel
                                  Generator, stationary
   23 - 91090            _                                       759 HP                _                   _                _                    _
                                  DD12 B1753, diesel
                                  Generator, MOS Boiler
   11 - 41703            _                                      980 HP                 _                   _                _                    _
                                  Operations, diesel

                                  Generator, portable,
   17 - 35738            _                                       980 HP                _                   _                _                    _
                                  diesel

                                  Generator, stationary PL
   21 - 71128            _                                       1620 HP               _                   _                _                    _
                                  13 SGCC, diesel
                                                                                                                 Northrop Grumman Shipbuilding, Inc.
                                                                                                                                          TRO-60153
                                                                                                                  Statement of Legal and Factual Basis
                                                                                                                                         June 1, 2009
                                                                                                                                               Page 9

                                                                              Pollution Control
                                 Emission Unit               Size/Rated                                                 Pollutant
Emission Unit ID     Stack ID                                                 Device (PCD)          PCD ID                              Applicable Permit Date
                                 Description                 Capacity*                                                  Controlled
                                                                              Description
                                 Generator, stationary
   34 - 36859             _                                      1479 HP               _                     _                _                    _
                                 B4636, diesel

                                 Generator, stationary
   58 - 39934             _                                      1479 HP               _                     _                _                    _
                                 FDD port, diesel

                                 Generator, stationary
   59 - 40005             _                                      1479 HP               _                     _                _                    _
                                 FDD STBD, diesel
  42030, 42031,
  42032, 42033,
                                 Eleven (11) Sullair 1300,
  42302, 42303,
                          _      Caterpillar diesel engine     480 HP each             _                     _                _                    _
  42304, 42305,
                                 / model 3406, diesel
  42306, 42307,
     42308
Foundry Operations


                                 Argon/Oxygen
                                                                                                                                             2/24/78 NSR
     550-E1                      Degassing Furnace,             25 ton/hr
                                                                                                                                           (CAM applicable)
                                 Whiting Corporation
                                                                              Cartridge Filter
     550-E2                      Electric Arc Furnace A          3 ton/hr     system, Donaldson
                        550-S1                                                Torit- Downflo Oval      550-C1a               PM
     550-E3                      Electric Arc Furnace B          3 ton/hr
                                                                              4-128, 99.9% design
                                                                              control efficiency                                                   _
     550-E4                      Electric Arc Furnace C          3 ton/hr

                                 Riser Burn Booth, hand
    550-E12                                                    0.068 ton/hr
                                 torches
                                                                                                                  Northrop Grumman Shipbuilding, Inc.
                                                                                                                                           TRO-60153
                                                                                                                   Statement of Legal and Factual Basis
                                                                                                                                          June 1, 2009
                                                                                                                                               Page 10

                                                                          Pollution Control
                               Emission Unit             Size/Rated                                                      Pollutant
Emission Unit ID   Stack ID                                               Device (PCD)               PCD ID                              Applicable Permit Date
                               Description               Capacity*                                                       Controlled
                                                                          Description
                               Charging/Tapping
    550-EF1             _                                   12.5 ton/hr              _                        _                _                    _
                               Operations

                               Pouring casting/Casting
    550-EF2             _                                   25 ton/hr                _                        _                _                    _
                               cooling Operation

    550-EF5             _      Shakeout Operations             NA                    _                        _                _                    _

                                                                              Dust collector
    550-E10             _      Abrasive Saw, #5453         0.02 tons/hr     venting inside the                _               PM                    _
                                                                                 building
                                                                            Baghouse, 95%
                               Steel Shot Abrasive
    550-E20          550-S20                                6 tons/hr       design control              550-C20               PM                    _
                               Blasting, #5610
                                                                               efficiency
                                                                          Cyclone, 70% design
    550-E21          550-S21   Sawing operation, #5616     0.01 tons/hr                                 550-C21               PM                    _
                                                                           control efficiency
                               Sand Reclaim                                Baghouse, Standard
    555-E11                                                12.5 tons/hr
                               Operations, hopper                          Havens Alpha Mark                                                      _
                     555-S11                                              III, size 24 SH, #34561,      555-C11               PM           (CAM applicable to
                               Riser Burn Area,                             95% design control                                                 555-E11)
    555-EF3                                                0.068 ton/hr
                               #34561, hand torches                               efficiency
                                                                          Cartridge filters, Torit
                               New Sand Operations,                         2DF12 Downflow,                                                       _
     555-E1           555-S1                               100 tons/hr                                   555-C1               PM
                               #40645, hopper                              #40645, 99% design                                               (CAM applicable)
                                                                            control efficiency
    528-EF1             _      Abrasive Blasting             50 lbs/hr               _                        _                _                    _

    528-EF2             _      Riser Burn Area                 NA                    _                        _                _                    _
                                                                                                                      Northrop Grumman Shipbuilding, Inc.
                                                                                                                                               TRO-60153
                                                                                                                       Statement of Legal and Factual Basis
                                                                                                                                              June 1, 2009
                                                                                                                                                   Page 11

                                                                                Pollution Control
                                   Emission Unit              Size/Rated                                                     Pollutant
Emission Unit ID   Stack ID                                                     Device (PCD)             PCD ID                              Applicable Permit Date
                                   Description                Capacity*                                                      Controlled
                                                                                Description
                                   Electric Induction
    556-EF1              _                                      0.5 to 4 tons             _                       _                _                    _
                                   Furnaces (4 each)

    556-EF2              _         Gas Furnace                     90 Lbs                 _                       _                _                    _

                                   Pouring casting/Casting
    556-EF3              _                                        4 ton/hr                _                       _                _                    _
                                   cooling Operation
Steel Preparation and Fabrication Operations


                                   Abrasive Blasting- Steel                        Pangborn Dust
    1746-E1        1476-S1         Shots, Pangborn               2.5 tons/hr    Collector, 95% design       1746-C1               PM                    _
                                   Rotoblast                                     control efficiency

                                                                                 Wheelabrator #19,
                                                                                 Model 126D, 95%
     274-E1        274-S1          Abrasive Shot Blasting        2.5 tons/hr                                 274-C1               PM                    _
                                                                                  design control
                                                                                    efficiency
                                                                                Pangborn C70, Type
     275-E5        275-S5          Abrasive Shot Blasting        2.5 tons/hr      CM, 95% design             275-C5               PM                    _
                                                                                 control efficiency
                                                                                 Torit dust collector,
                                                                                 Downflow DFT4-16
                                   Wire Brush Paint
     276-E3        276-S3                                            _           cartridge filter, 99%       276-C3               PM                    _
                                   Removal
                                                                                    design control
                                                                                       efficiency
                   Building
   276-E3PC                        Plasma Cutting                    _                    _                       _                _                    _
                   vents
                                                                                                           Northrop Grumman Shipbuilding, Inc.
                                                                                                                                    TRO-60153
                                                                                                            Statement of Legal and Factual Basis
                                                                                                                                   June 1, 2009
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                                                                           Pollution Control
                               Emission Unit              Size/Rated                                              Pollutant
Emission Unit ID   Stack ID                                                Device (PCD)           PCD ID                          Applicable Permit Date
                               Description                Capacity*                                               Controlled
                                                                           Description
                                                                            RF Cox Associates
                               Abrasive Blasting- Steel                      baghouse, 95%
     288-E1        288-S1                                    2.5 tons/hr                              288-C1           PM                    _
                               shots                                         design control
                                                                                efficiency
                                                                            RF Cox Associates
                               Abrasive Blasting- Steel                      baghouse, 95%
     288-E2        288-S2                                    2.5 tons/hr                              288-C2           PM                    _
                               shots                                         design control
                                                                                efficiency
                                                                            RF Cox Associates
                               Abrasive Blasting- Steel                      baghouse, 95%
     288-E3        288-S3                                    2.5 tons/hr                              288-C3           PM                    _
                               shots                                         design control
                                                                                efficiency
                                                                            RF Cox Associates
                                                                             baghouse, 95%
                               Abrasive Blasting- Steel                      design control
     288-E4        288-S4                                    2.5 tons/hr                              288-C4           PM                    _
                               shots                                            efficiency


Secondary Lead Processing

                                                                           Baghouse, Standard
4582-E1 through                Lead Contouring Hot           4.7 tons/hr   Havens Alpha Mark
                     4582-S1                                                                         4582-C1           PM           12/16/81 NSR permit
      E6                       Benches                       combined      III 18, 99.0% design
                                                                           control efficiency
                                                                           Baghouse, Standard
                               Lead Casting Furnaces                       Havens Alpha Mark
    4582-E12         4582-S2                                 4.7 tons/hr                             4582-C2           PM           12/16/81 NSR permit
                               and Conveyor System                         III 18, 99.0% design
                                                                           control efficiency
                                                                                                                  Northrop Grumman Shipbuilding, Inc.
                                                                                                                                           TRO-60153
                                                                                                                   Statement of Legal and Factual Basis
                                                                                                                                          June 1, 2009
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                                                                               Pollution Control
                                  Emission Unit              Size/Rated                                                  Pollutant
Emission Unit ID   Stack ID                                                    Device (PCD)           PCD ID                             Applicable Permit Date
                                  Description                Capacity*                                                   Controlled
                                                                               Description
                                                                               Baghouse, Standard
                                  Lead School (for
                                                                               Havens Alpha Mark
     LS-E1            4582-S3     training) with 3 work        0.05 tons/hr                              4582-C3              PM           12/16/81 NSR permit
                                                                               III 18, 99.0% design
                                  stations
                                                                               control efficiency
Wood Working
                                                                                  Cyclone, 90.0%
      3-E1             3-S1       Cutting/Planer/Re-saw              _            design control           3-C1               PM                    _
                                                                                    efficiency
                                                                                  Cyclone, 90.0%
                                  Foundry Pattern Shop -
     501-E2           501-S2                                         _            design control          501-C2              PM                    _
                                  wood cutting machines
                                                                                    efficiency
                                                                                  Cyclone, 90.0%
     513-E1           513-S1      Warehouse No. 6 Saws               _            design control          513-C1              PM                    _
                                                                                    efficiency
Electroplating
                                  Chromium electroplating
   PLATE-E1                        tank #63, Plateg Corp.,     129 ft 3/hour
                                        POP-68919-R
                                                                               Zenon packed tower
                      4620-S1     Chromium electroplating                      scrubber, 98.0%
   PLATE-E2                        tank #49, Plateg Corp.,      32 ft 3/hour                             4620-C1              PM                    _
                                                                               design control
                                        POP-68919-R                            efficiency
                                  Chromium electroplating
   PLATE-E3                        tank #59, Plateg Corp.,     129 ft 3/hour
                                        POP-68919-R
Painting Operations

Painting Operations/Group P-X33
                                                                                                        Northrop Grumman Shipbuilding, Inc.
                                                                                                                                 TRO-60153
                                                                                                         Statement of Legal and Factual Basis
                                                                                                                                June 1, 2009
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                                                                        Pollution Control
                                Emission Unit              Size/Rated                                           Pollutant
Emission Unit ID   Stack ID                                             Device (PCD)           PCD ID                          Applicable Permit Date
                                Description                Capacity*                                            Controlled
                                                                        Description
                                                                                Binks
                                Consolidated Paint
                                                                          Dynaprecipitator,
 232-E1 through    232-S1       Facility, 2 banks of 3                                         232-C1 through
                                                                  _      water wash curtain,                    PM-10          _
       E6          through S6   paint booths each (6                                                C6
                                                                         98% design control
                                total)
                                                                              efficiency
                                                                              Greenline
                                Metal Finishing Bldg,
                                                                         Corporation, water
                                paint booth (Zn
    4681-E2          4681-S2                                      _      wash curtain, 98%        4681-C2       PM-10          _
                                phosphate coating line),
                                                                            design control
                                automated
                                                                              efficiency
                                                                              Greenline
                                                                         Corporation, water
                                Metal Finishing Bldg,
    4681-E3          4681-S3                                      _      wash curtain, 98%        4681-C3       PM-10          _
                                paint booth, manual
                                                                            design control
                                                                              efficiency
                                                                          Global Finishing
                                Aluminum Wire Flame                     Solutions water wash
    4701-E10         4701-S10                                     _                               4701-C10      PM-10          2/12/86 NSR permit
                                Spray booth, manual                     curtains, 98% design
                                                                         control efficiency

                                                                          Global Finishing
                                Aluminum Wire Flame                     Solutions water wash
    4701-E11         4701-S11                                     _                               4701-C11      PM-10          2/12/86 NSR permit
                                Spray booth, manual                     curtains, 98% design
                                                                         control efficiency

                                                                          Global Finishing
                                Flame Spray Facility
                                                                        Solutions water wash
    4701-E12         4701-S12   paint booth, north unit,          _                               4701-C12      PM-10          2/12/86 NSR permit
                                                                        curtains, 98% design
                                manual
                                                                         control efficiency
                                                                                                              Northrop Grumman Shipbuilding, Inc.
                                                                                                                                       TRO-60153
                                                                                                               Statement of Legal and Factual Basis
                                                                                                                                      June 1, 2009
                                                                                                                                           Page 15

                                                                        Pollution Control
                                Emission Unit              Size/Rated                                                Pollutant
Emission Unit ID   Stack ID                                             Device (PCD)            PCD ID                               Applicable Permit Date
                                Description                Capacity*                                                 Controlled
                                                                        Description
                                                                          Global Finishing
                                Flame Spray Facility
                                                                        Solutions water wash
    4701-E13         4701-S13   paint booth, south unit,          _                                4701-C13          PM-10           2/12/86 NSR permit
                                                                        curtains, 98% design
                                manual
                                                                         control efficiency

                                                                          Filter (paper), JBI
                                Paint Spray Bldg,                         Automatic Spray
    4702-E1          4702-S1                                      _                             4702-C1              PM-10                      _
                                antenna paint booth                      Booth, 90% design
                                                                         control efficiency

                                Grit Blast & Paint                       Filter (paper), 90%
    4730-NP         4730-NPFE   Facility, North Paint             _        design control       4730-NPC             PM-10                      _
                                Room                                          efficiency


                                Grit Blast & Paint
    4730-SP         4730-SPFE   Facility, South Paint             _      Filter (paper), 90%    4730-SPC             PM-10                      _
                                Room                                       design control
                                                                              efficiency
Painting Operations/P-SHIPSPRAY


                                Outside Vessel
 P-SHIPSPRAY            _       Painting- manual spray            _               _                       _                  _                  _
                                painting
Painting Operations/P-SHIPBRUSH
                                                                                                                     Northrop Grumman Shipbuilding, Inc.
                                                                                                                                              TRO-60153
                                                                                                                      Statement of Legal and Factual Basis
                                                                                                                                             June 1, 2009
                                                                                                                                                  Page 16

                                                                                  Pollution Control
                                 Emission Unit                Size/Rated                                                    Pollutant
Emission Unit ID   Stack ID                                                       Device (PCD)          PCD ID                              Applicable Permit Date
                                 Description                  Capacity*                                                     Controlled
                                                                                  Description
                                 General facility-wide
                                 marine coating
                                 operations, brush, roller,
                                 and touch-up
 P-SHIPBRUSH            _        application on vessels              _                     _                     _                _                    _
                                 and vessel parts-
                                 manual brush painting



Painting Operations/Powder Coating Operation
                                                              One burner rated
                                     Parts Washer with        at 2.0
    205-C1a           205-C1aS
                                     three burners,           MMBTU/hr and
    205-C1b           205-C1bS                                                             _                     _                _         2/14/01 NSR Permit
                                     natural gas-fired,       two burners rated
    205-C1c           205-C1cS
                                     Eclipse Imersojet IJ6    at 1.3
                                                              MMBTU/hr each
                                                                  Burner and
                                     Preheat oven,
                                                               evaporator rated
     205-C2            205-C2S       natural gas-fired,                                    _                     _                _         2/14/01 NSR Permit
                                                                     at 5.5
                                     Eclipse AH520
                                                                 MMBTU/hr
                                                                  Burner and
                                     Cure oven, , natural
                                                               evaporator rated
     205-C3            205-C3S       gas-fired, Eclipse                                    _                     _                _         2/14/01 NSR Permit
                                                                     at 5.5
                                     AH520
                                                                 MMBTU/hr
                                     Heat cleaning oven,                              Direct Flame
                                     propane-fired,                                Afterburner, 99.0%
     206-C1            206-C1S                                 0.6 MMBTU/hr                                206-C1C               VOC        2/14/01 NSR Permit
                                     Steelman Model                                  design control
                                     4.56.54 BA-C                                      efficiency
                                                                                                                       Northrop Grumman Shipbuilding, Inc.
                                                                                                                                                TRO-60153
                                                                                                                        Statement of Legal and Factual Basis
                                                                                                                                               June 1, 2009
                                                                                                                                                    Page 17

                                                                                Pollution Control
                                  Emission Unit               Size/Rated                                                      Pollutant
Emission Unit ID   Stack ID                                                     Device (PCD)              PCD ID                              Applicable Permit Date
                                  Description                 Capacity*                                                       Controlled
                                                                                Description
                                      Nordson Powder
    205-PDR               _           Booth, powder            2,160 lbs/hour             _                        _                _         2/14/01 NSR permit
                                      coating booth
Painting Operations/Group P-X15
                                      Plate Preparation &                       Dry filter (paper), 90%
    274-E13            274-S13        Inspection, paint              _          design control               274-C13              PM-10                  _
                                      booth                                     efficiency
                                                                                Dry filter (paper), 90%
 275-E4 and 275-    275-S4 and 275-   Shape Preparation,                                                  275-C4 and 275-
                                                                     _          design control                                    PM-10                  _
       E6              S6, resp.      paint booths (two)                                                     C6, resp.
                                                                                efficiency
                                      Plate Preparation &                       Filter (paper), ESAB-
    1746-E4            1746-S4        Inspection, paint              _          HEBE, 90% design             1746-C4              PM-10                  _
                                      booth                                     control efficiency

     60-E5                _           Engraving                      _                    _                        _                _                    _
Painting Operations/Group P-FAC
                                      General facility-wide
                                      non-vessel brush,
                                      roller, spray and
     P-FAC                _           touch-up painting              _                    _                        _                _                    _
                                      operations- manual
                                      brush and spray
                                      painting
                                                                                                             Northrop Grumman Shipbuilding, Inc.
                                                                                                                                      TRO-60153
                                                                                                              Statement of Legal and Factual Basis
                                                                                                                                     June 1, 2009
                                                                                                                                          Page 18

                                                                          Pollution Control
                                 Emission Unit               Size/Rated                                             Pollutant
Emission Unit ID   Stack ID                                               Device (PCD)           PCD ID                             Applicable Permit Date
                                 Description                 Capacity*                                              Controlled
                                                                          Description
                                                                           Filter (paper), 90%
                                    Maintenance Shop,
     103-E2             103-S2                                      _        design control          103-C2             PM-10                  _
                                    paint booth
                                                                                efficiency

Specialty Shops

                                     Electrical Shop drill                   Baghouse, 95%
     64-E1              64-S1         press/sander (not             _        design control          64-C1               PM                    _
                                       used for wood)                          efficiency
                                                                            Baghouse, 95%
     64-E2              64-S2        Electrical Shop saw            _        design control          64-C2               PM                    _
                                                                               efficiency
                                                                          Cyclone, 90% design
     64-E9              64-S9          Grinding metal               _                                64-C9               PM                    _
                                                                           control efficiency
                                                                            Cartridge filters
                                                                            Donaldson Torit
     60-E2              60-S2       Grinding operations             _     Downflow DFO3-12,          60-C2               PM                    _
                                                                          99% design control
                                                                               efficiency
                                                                            Cartridge filters
                                                                            Donaldson Torit
     114-E1             114-S1           Saw metals                 _      Downflow 2DF8,            114-C1              PM                    _
                                                                          #40859, 99% design
                                                                           control efficiency
                                         Melamine
                                                                             Dust collector,
                                      Operations (2
                                                                            Donaldson Torit
    4896-E1            4896-S1       Milling Machines,              _                               4896-C1              PM                    _
                                                                          Model 90-219-5, 99%
                                      Band Saw, and
                                                                           control efficiency
                                           Lathe)
                                                                                                                          Northrop Grumman Shipbuilding, Inc.
                                                                                                                                                   TRO-60153
                                                                                                                           Statement of Legal and Factual Basis
                                                                                                                                                  June 1, 2009
                                                                                                                                                       Page 19

                                                                                  Pollution Control
                                      Emission Unit              Size/Rated                                                      Pollutant
Emission Unit ID   Stack ID                                                       Device (PCD)               PCD ID                              Applicable Permit Date
                                      Description                Capacity*                                                       Controlled
                                                                                  Description
                                           Bayco burn-out
                                          oven, Model BB-                             Afterburner, 1
     64-E3                  64-S3                                 1 MMBTU/hr                                     64-C3                PM          10/18/1979 NSR Permit
                                         288, using propane,                           MMBTU/hr
                                                 1979
                                          Facility-wide parts-
    FAC-PW           Building vents                                     _                    _                        _                _                    _
                                          washer operations
Miscellaneous Activities

                                          External abrasive
   FAC-BLST                  _            blasting - facility-          _
                                                                                             _                        _                _                    _
                                                 wide
                                            Utility grit off-
   FAC-GRIT                  _                                          _
                                               loading                                       _                        _                _                    _
                                            Wheelabrator                          Cartridge filters, Torit
                                         #11980 Table Blast                       Ultraweb Downflow II
     50-E1                  50-S1                                   2.5 tons/hr                                  50-C1                PM                    _
                                           Unit -Abrasive                         DFT3-12, 99% design
                                         blasting/steel shots                     control efficiency
                                          Abrasive blasting
                                         glove box/sand and
     17-E20                  _                                          _                    _                        _                _                    _
                                         glass, Vacublast 93-
                                                 2788
                                                                                      Torit Ultraweb
                           4730-NR             Abrasive                               Cartridge Dust
    4730-NB            (Northside        blasting/steel shot -          _            collector, 99.0%          4730-NRC               PM                    _
                        Reclaim)          North Blast Room                            design control
                                                                                        efficiency
                                                                                                                    Northrop Grumman Shipbuilding, Inc.
                                                                                                                                             TRO-60153
                                                                                                                     Statement of Legal and Factual Basis
                                                                                                                                            June 1, 2009
                                                                                                                                                 Page 20

                                                                                Pollution Control
                                   Emission Unit               Size/Rated                                                   Pollutant
Emission Unit ID   Stack ID                                                     Device (PCD)              PCD ID                           Applicable Permit Date
                                   Description                 Capacity*                                                    Controlled
                                                                                Description
                                                                                    Torit Ultraweb
                      4730-NLE                                                      Cartridge Dust
                   (Northside Local                                   _            collector, 99.0%          4730-NLC            PM                   _
                      Exhaust)                                                      design control
                                                                                      efficiency

                       4730-SR                                                      Torit Ultraweb
                                                                                    Cartridge Dust
                      (Southside                                      _                                      4730-SRC            PM                   _
                                                                                   collector, 99.0%
                       Reclaim)                                                     design control
                                            Abrasive
    4730-SB                           blasting/steel shot -                         Torit Ultraweb
                      4730-SLE         South Blast Room                             Cartridge Dust
                   (Southside Local                                   _            collector, 99.0%          4730-SLC            PM                   _
                       Exhaust)                                                     design control
                                                                                      efficiency
                                           Abrasive                             Cartridge filters Torit
                                      blasting/steel shot                       UltraWeb Downflow
     201-E1             201-S1                                    2.5 tons/hr                                 201-C1             PM                   _
                                          (10/1970),                            DFO3-12, 99% design
                                      Wheelabrator #7614                         control efficiency
                                                                                Baghouse, Standard
                                                                                Havens 12SH Alpha
                                            Abrasive
    Port-E1            Port-S1                                        _           Mark III, 95.0%            Port-C1             PM                   _
                                       blasting/steel shot
                                                                                  design control
                                                                                    efficiency
                                                                                  Baghouse, Torit
Port-E2 through    Port-S2 through          Abrasive                            Model MTD-48-LD,          Port-C2 through
                                                                      _                                                          PM                   _
    Port E-3           Port-S3         blasting/utility grit                    95.0% design control          Port-C3
                                                                                     efficiency
                                                                                                                   Northrop Grumman Shipbuilding, Inc.
                                                                                                                                            TRO-60153
                                                                                                                    Statement of Legal and Factual Basis
                                                                                                                                           June 1, 2009
                                                                                                                                                Page 21

                                                                              Pollution Control
                                  Emission Unit               Size/Rated                                                  Pollutant
Emission Unit ID   Stack ID                                                   Device (PCD)            PCD ID                              Applicable Permit Date
                                  Description                 Capacity*                                                   Controlled
                                                                              Description
                                                                              Baghouses (21 units),
                                                                              Vaculblast Co. Model
Port-E4 through    Port-S4 through         Abrasive                                                   Port-C4 through
                                                                     _        D6 or D6S-8W, 95.0%                              PM                    _
   Port E-24           Port-S24       blasting/utility grit                                               Port-C24
                                                                                 design control
                                                                                efficiency, each
                                                                                  Baghouse,
                                                                              MISCO/IPEC custom-
                                           Abrasive
    Port-E25           Port-S25                                      _         made unit, 95.0%          Port-C25              PM                    _
                                      blasting/utility grit
                                                                                design control
                                                                                  efficiency
                                                                              Baghouses (6 units),
                                                                              MISCO/IPEC custom-
Port-E26 through   Port-S26 through        Abrasive                                                   Port-C26 through
                                                                     _         made units, 95.0%                               PM                    _
    Port-E31           Port-S31       blasting/utility grit                                               Port-C31
                                                                                 design control
                                                                                efficiency, each
                                                                                   Baghouse,
                                           Abrasive
                                                                              MISCO/IPEC custom-
                                      blasting/steel grit,
    4701-E1            4701-S1                                   384 lbs/hr    made units, 95 %           4701-C1              PM                    _
                                      garnet, aluminum
                                                                                 design control
                                             oxide
                                                                                   efficiency
                                      Grinding/cutting/we                        Cyclone, Torit,
    1768-E1            1768-S1          lding - Welding              _         90 % design control        1768-C1              PM                    _
                                            School                                 efficiency
                                      Welding- facility-
  FAC-WELD                _                                          _                 _                       _                _                    _
                                            wide
                                                                                                                  Northrop Grumman Shipbuilding, Inc.
                                                                                                                                           TRO-60153
                                                                                                                   Statement of Legal and Factual Basis
                                                                                                                                          June 1, 2009
                                                                                                                                               Page 22

                                                                          Pollution Control
                                 Emission Unit            Size/Rated                                                     Pollutant
Emission Unit ID   Stack ID                                               Device (PCD)               PCD ID                              Applicable Permit Date
                                 Description              Capacity*                                                      Controlled
                                                                          Description
                                                                           Fabric filter, Portable
                                                                          Hawley TRAV-L vent
                                       Welding/lead                          fabric filter with
     250-E1             250-S1                                   _                                       250-C1               PM                    _
                                    caulking operations                      HEPA filter dust
                                                                          collector, 95 % design
                                                                            control efficiency
                                                                           Fabric filter, Portable
                                                                          Hawley TRAV-L vent
                                                                             fabric filter with
     263-E1             263-S1      Welding operations           _           HEPA filter dust            263-C1               PM                    _
                                                                             collector, 95.0%
                                                                              design control
                                                                                efficiency
                                                                            Baghouse, 95.0%
    4677-E1            4677-S1      Welding operations           _            design control            4677-C1               PM                    _
                                                                                efficiency
                                                                           Fabric filter, Portable
                                                                          Hawley TRAV-L vent
                                                                             fabric filter with
                                        Arc gouger
     250-E2             250-S2                                   _           HEPA filter dust            250-C2               PM            9/02/94 NSR permit
                                        operations
                                                                             collector, 95.0%
                                                                              design control
                                                                                efficiency
                                     Gluing operations-
  FAC-GLUE                _                                      _                   _                        _                _                    _
                                        facility-wide
                                     Abrasive blasting
                                    using ALC portable
    ALC-E1                _                                  800 lbs/hr              _                        _                _                    _
                                     blasting machine,
                                    Model F-600R, 2006
                                                                                                                 Northrop Grumman Shipbuilding, Inc.
                                                                                                                                          TRO-60153
                                                                                                                  Statement of Legal and Factual Basis
                                                                                                                                         June 1, 2009
                                                                                                                                              Page 23

                                                                             Pollution Control
                                 Emission Unit              Size/Rated                                                  Pollutant
Emission Unit ID   Stack ID                                                  Device (PCD)           PCD ID                              Applicable Permit Date
                                 Description                Capacity*                                                   Controlled
                                                                             Description
                                                                                 Low efficiency
     501-E5             501-S5       Asbestos cutting             NA                                    501-C5               PM                    _
                                                                                     cyclone
                                                                              Dust Collector work
                                      Asbestos & non-                         bench, Torit Model
     75-E5              75-S5        asbestos cutting of          NA           DD or Model 130,         75-C5                PM                    _
                                          gaskets                                design control
                                                                              efficiency unknown
                                                                               Baghouse, 95.0%
                                       Polyethylene
     74-E1              74-S1                                     NA             design control         74-C1                PM                    _
                                          cutting
                                                                                    efficiency
                                      Solvent/thinner
  FAC-SOLV                _                                        _                  _                      _                _                    _
                                    usage- facility-wide
                                         Fiberglass
     175-E1               _                                        _                  _                      _                _                    _
                                         operations
 SS-E1 through                       Service stations -
                          _                                        _                  _                      _                _                    _
     SSE2                                gasoline
                                       Wheelabrator                          Baghouse,
                                    /Tumblast Machine                        Wheelabrator
      5-E2               5-S2          (Blast Unit)-           2.5 tons/hr   Dustube Model 112-          5-C2                PM                    _
                                     Abrasive Blasting                       AC, 95.0% design
                                       /steel shots                          control efficiency
                                                                                 Baghouse,
                                      Powder coating                         Wheelabrator USF 44,
     205-B1             205-S1                                     _                                   205-BC1               PM               2/14/01 NSR
                                    steel shot blast unit                      design control
                                                                               efficiency 95%
                                                                             Baghouse, Pangborn
                                      Powder coating                          Model 25-5-8, Type
     205-B2             205-S2                                     _                                   205-BC2               PM               2/14/01 NSR
                                    steel shot blast unit                    HP-1, design control
                                                                               efficiency 95%
                                                                                                                    Northrop Grumman Shipbuilding, Inc.
                                                                                                                                             TRO-60153
                                                                                                                     Statement of Legal and Factual Basis
                                                                                                                                            June 1, 2009
                                                                                                                                                 Page 24

                                                                               Pollution Control
                                   Emission Unit            Size/Rated                                                     Pollutant
Emission Unit ID   Stack ID                                                    Device (PCD)            PCD ID                              Applicable Permit Date
                                   Description              Capacity*                                                      Controlled
                                                                               Description
Site Remediation
                           _                   _                    _                    _                      _                _                    _
    Activities
*The Size/Rated capacity is provided here for informational purposes only, and is not an applicable requirement.
                                                                                          Northrop Grumman Shipbuilding, Inc.
                                                                                                                   TRO-60153
                                                                                           Statement of Legal and Factual Basis
                                                                                                                  June 1, 2009
                                                                                                                       Page 25


V. EMISSIONS INVENTORY
A copy of the 2007 annual emission update is attached. Emissions are summarized in the following table. Note that the facility is
major for HAPs; however, HAPs emissions are included in PM-10 or VOC emissions except for those classified as non-VOC non-
PM HAPs which are not emitted in significant amounts at the facility. For 2007, the non-VOC non-PM HAP emissions were 0.1
tons/year.

                                                   2007 Actual Emissions

                                             2007 Criteria Pollutant and HAP Emissions in Tons/Year

                                                                                                                   Non-VOC
                         VOC                CO                SO2                PM10              NOx
                                                                                                                 non-PM HAPs
                                                                                                                       0.1
 Facility-Wide           155.9              27.3              997.4              98.9              480.5
 Total




VI.     FUEL BURNING EQUIPMENT REQUIREMENTS
                  A. Limitations

The following Virginia Administrative Codes that have specific emission requirements have been determined to be applicable to
the boilers at the facility (Units FTSF-E1, FTSF-E2, and 78-E1 through E3):
         9 VAC 5 Chapter 40          Existing Stationary Sources
         9 VAC 5 Chapter 40          Article 8: Emission Standards for Fuel Burning Equipment
                                     9 VAC 5-40-900. Standard for particulate matter
                                     9 VAC 5-40-930. Standard for Sulfur Dioxide
                                     9 VAC 5-40-940 B. Standard for Visible Emissions

The boiler fuel is limited to 2.1% sulfur and the SO2 emission limit is 2.23 lbs/MMBTU (1/13/85 NSR permit).
The standards for particulate matter and SO2 are met using AP-42 emission factor as shown below:
Total capacity = (213.26 x 2) + (135 x 3) = 831.52 MMBTU/hr combined or 5,544 gal/hr maximum fuel feed combined.
PM standard (lbs/MMBTU) = 1.0906(831.52) -0.2594 = 0.175 lbs/MMBTU
AP-42 (Table 1.3.1, 9/98) PM emission Factor        = 9.19(S) +3.22 lbs/1000 gallons No. 6 fuel oil.
                                                    = (9.19 x 2.1) + 3.22= 22.52 lbs/1000 gal
                                                    = 22.52 lbs/ (1000 gal x 0.15 MMBTU/gal) = 0.150 lbs/MMBTU
SO2 standard (lbs/hr) = 2.64 x total capacity in MMBTU/hr= 2.64 x 831.52= 2195.2 lbs/hr
                                                    = 2195.2 lbs/hr / 831.52 MMBTU/hr= 2.64 lbs/MMBTU
AP-42 (Table 1.3.1, 9/98) SO2 emission Factor = 157(S) lbs/1000 gallons No. 6 fuel oil
                                                    = 157(2.1) lbs/ (1000 gal x 0.15 MMBTU/gal) = 2.198 lbs/MMBTU

The fuel oil #2 annealing oven (Unit 1278-S1) and the propane-fired ovens/furnaces (276-E1, 276-E2, 550-E8, 550-E9, and
550-E13) are also subject to the above Virginia Administrative Codes for existing source standards. Compliance to the PM and
SO2 emission standards using AP-42 emission factors can readily be demonstrated similarly to above.
                                                                                         Northrop Grumman Shipbuilding, Inc.
                                                                                                                  TRO-60153
                                                                                          Statement of Legal and Factual Basis
                                                                                                                 June 1, 2009
                                                                                                                      Page 26

All above-mentioned units are subject to the opacity limits of 9 VAC 5-40-940 B. Note that the opacity requirements of 9 VAC
5-40-940 B do not apply to the barge-mounted boilers FTSF-E1 and FTSF-E2. These barge-mounted units provide power to
test aircraft carriers in lieu of nuclear power. They fall under 9 VAC 5-40-5680- Other Mobile Sources, and as such, have
historically been exempted from opacity requirements under 9 VAC 5-40-5680 C (a) and (b).

Miscellaneous diesel internal combustion engines for power generation or mechanical uses which do not qualify as
Insignificant Activities (9 VAC 5-80-720) are subject to the opacity limits of 9 VAC 5-40-80 if they are pre-1972, or the
opacity limits of 9 VAC 5-50-80 if they are newer.

The two newly-installed boilers (TS-E1 and TS-E2), 245 MMBTU/hr each, are permitted by 6/04/07 NSR. They are subject
to NSPS Subpart Db and, at the time of the NSR permit issuance, MACT Subpart DDDDD. As the MACT rule was vacated
on July 30, 2007, its applicable requirements cited in the NSR permit are streamlined. As the boilers burn only very low sulfur
distillate oil, those MACT requirements were not numerous (see Streamlined Requirements below). Note that Condition 14 of
the NSR permit has an inadvertent typographical error in citing NSPS Subpart Dc instead of Db which is corrected in
Condition III.A.14 of the Title V permit.

                  B. Monitoring and Recordkeeping

The new boilers TS-E1 and TS-E2 have an NSR permit with clearly stated monitoring and recordkeeping conditions including
a CEMS for NOx which can be directly carried over to the Title V permit. For other units, periodic monitoring and
recordkeeping requirements are added to demonstrate compliance with applicable PM, SO2 and opacity limits from Virginia
Administrative Codes. Monthly visible emissions evaluations (VEE) by EPA Method 9 (40 CFR 60, Appendix A) are required
for steam plant boilers 78-E1 through E3 while tiered requirements are required for other fuel burning equipments (276-E1,
276-E2, 550-E8, 550-E9, 550-E13, and 1278-E1), starting with visible emissions observations, followed by Method 9 VEE if
any observed opacity cannot be eliminated by corrective actions. For the numerous diesel internal combustion engines, it was
deemed unnecessary to require periodic visible emissions testing as they are relatively small in size even though they do not
qualify as Insignificant Activities (9 VAC 5-80-720).

                  C. Testing

Initial performance test is required to demonstrate compliance with the lbs NOx/MMBTU emission limit for boilers TS-E1 and
TS-E2 using the continuous emissions monitoring systems (CEMS) as stated in Condition 18 of the 6/04/07 NSR. There are
no other required tests other than the periodic monitoring described above. The Department and EPA have authority to require
testing not included in this permit if necessary to determine compliance with an emission limit or standard.

                  D. Reporting

The permittee is required to submit performance test data from the initial compliance test, quarterly/semi-annual excess NOx
emission reports, and semi-annual fuel quality reports for boilers TS-E1 and TS-E2 as required by 6/04/07 NSR.

                  E. Streamlined Requirements

Condition 14 of 6/04/07 NSR for boilers TS-E1 and TS-E2: reference to MACT Subpart DDDDD is removed because the rule
has been vacated.

Condition 19 of 6/04/07 NSR for boilers TS-E1 and TS-E2: Initial notification requirements have already been met.
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VII. FOUNDRY OPERATIONS REQUIREMENTS
                  A. Limitations

Only the Argon Oxygen Degassing (AOD, Unit Ref. No. 550-E1) furnace has an NSR permit dated 2/24/78. However, there
are no applicable requirements in the permit except for a brief mention of visible emissions evaluation requirement.

The following Virginia Administrative Codes that have specific emission requirements have been determined to be applicable to
the foundry emission units:
         9 VAC 5 Chapter 40      Existing Stationary Sources
         9 VAC 5 Chapter 40      Article 18: Emission Standards for Primary and Secondary Metal Operations
                                 9 VAC 5-40-2410. Standard for particulate matter
                                 9 VAC 5-40-2430. Standard for visible emissions, referencing 9 VAC 5-40-60 et seq.
         9 VAC 5 Chapter 50      New and Modified Stationary Sources
                                 9 VAC 5-50-80. Standard for visible emissions

The foundry operations are also subject to 40 CFR 63 Subpart EEEEE- National Emission Standards for Hazardous Air
Pollutants for Iron and Steel Foundries. The affected facilities at the site have been determined to be the three Electric Arc
Furnaces (550-E2, 550-E2 and 550-E3) and fugitive emissions from buildings 550 that house affected units that do not emit
through a conveyance pursuant to 40 CFR 63.7682 (b) and 40 CFR 63.7690 (a)(7). Note that fugitive emissions from
buildings 526 and 556 have been determined as not subject to the MACT. The facility operations also do not have other types
of affected facilities such as cupola, automated conveyors, etc. The PM emission limit is 0.005 grains/dscf (40 CFR 63.7690
(a)(1)) which is more stringent than from 9 VAC 5-40-2410. The MACT does not specify opacity limits except for the
fugitive emissions (opacity shall not be 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))).

The AOD is not subject to MACT Subpart EEEEE even though it is in the same building and its particulate emissions are also
controlled by the same cartridge particulate removal system which satisfies MACT requirements. On the other hand, it is
subject to the Compliance Assurance Monitoring (CAM) requirements of 40 CFR 64 as discussed below.

                  B. Monitoring and Recordkeeping

Pre-control emissions from all units with pollution control devices are estimated. The units with pre-control emissions above
100 tons/year for any regulated pollutant are subject to CAM. CAM plans for those pre-control major emission units that have
controlled emissions below the major source levels are due at the time of Title V permit renewal. Those units are identified as
the AOD (550-E1) as mentioned above, the New Sand Operation (555-E1), and the Sand Reclaim Operation (555-E11).
Control device for the AOD is a high efficiency cartridge particulate removal system (550-C1a) which also controls emissions
from the Electric Arc Furnaces. Control device for the New Sand Operation and the Sand Reclaim Operation are cartridge
filter (555-C1) and baghouse (555-C11), respectively. CAM requirements to the units and their pollution control devices are
described in detail using DEQ boilerplate conditions. Note that Condition IV.B.13 states that a Quality Improvement Plan (QIP)
is triggered if "the number of excursions exceeds the threshold set" for each unit, instead of the boilerplate language "the
number of exceedances or excursions exceeds 5 percent duration of the operating time for the [CAM-affected unit]" for a
semiannual reporting period. The CAM rule at 40 CFR 64.8 was reviewed and found that the 5 percent number is intended to
be an example only, not a fixed figure for all situations; a specific threshold number appropriate for each unit should satisfy the
CAM requirements.

Periodic monitoring to demonstrate compliance to the opacity limit in 9 VAC-5-50-80 for the AOD (550-E1) is also required;
Method 9 visible emission evaluation is carried out once every 6 months on its stack 550-S1 (Condition IV.B.3).
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All monitoring requirements of MACT Subpart EEEEE applicable to the Electric Arc Furnaces (550-E2 through E3) are
described, including work practice standards, Operation and Maintenance Plan, Startup Shutdown and Malfunction Plan, initial
compliance demonstrations, monitoring device requirements, and continuing monitoring requirements. The monitoring device
used for the cartridge particulate removal system to meet MACT requirements is a Triboguard bag (cartridge) leak detection
system.

Most other units not subject to CAM or MACT have pollution control devices that ensure compliance with the PM standards in
9 VAC 5-40-2410. This can be readily shown with calculations using AP-42 emission factors, rated capacity, and appropriate
control efficiency. In addition, permit Condition IV.B.4 requires monthly visible emission observations for 550-E20 stack,
followed by, if necessary, visible emission evaluations by EPA Method 9 (40 CFR 60 Appendix A) to demonstrate continuing
compliance with visible emission limits. Note that those units that are already subject to CAM and/or MACT (Stacks 550-S1,
555-S1, and 555-S11) are not subject to this requirement. Riser Burn Booth 550-E12 shares the same stack (550-S1) with the
Electric Arc Furnaces, and Riser Burn Area 555-EF3 shares the same stack (555-S11) with the Sand Reclaim Operation (555-
E11). Also, 550-E21 is a small abrasive saw for cutting small pieces of steel that are hand-held and require less than a minute
to cut per piece. It also has a cyclone for PM emissions control. Hence, periodic visible emission observations for 6-minutes
are deemed unnecessary.

Records of all monitoring, testing, notifications and reports, including those required by MACT Subpart EEEEE are to be kept
available onsite for inspection by the DEQ and shall be current for the most recent five (5) years unless otherwise noted.

                  C. Testing

MACT Subpart EEEEE specifies initial performance test and subsequent performance tests for PM emissions from the Electric
Arc Furnaces and opacity of affected fugitive emissions. Note that EPA Method 9 is required for the fugitive emissions, not
Method 22, pursuant to 40 CFR 63.7732(d). Subsequent performance test is required to be no less frequently than every 5
years for PM, and no less frequently than once every 6 months for fugitive opacity (40 CFR 63.7731(b)). Note that the every-
six-month frequency is clarified in Condition IV.D.3 of the permit by facility's request to ensure that it does not mean exactly 6
months from the day of the previous test. The 5-year testing frequency for PM is not waived here because the units do not
have Continuous Emissions Monitoring System (CEMS) as cited in 40 CFR 63.7731(a). Initial compliance demonstration for
work practices and the bag leak detection system are also specified.

                  D. Notifications and Reporting

Applicable requirements from MACT Subpart EEEEE and CAM are described.

VIII. STEEL PREPARATION AND FABRICATION OPERATIONS REQUIREMENTS
                  A. Limitations

There are no underlying NSR permits for these operations.

The following Virginia Administrative Codes that have specific emission requirements have been determined to be applicable to
the steel preparation and fabrication emission units:
         9 VAC 5 Chapter 40         Existing Stationary Sources
         9 VAC 5 Chapter 40         Article 4: Emission Standards for General process Operations
                                    9 VAC 5-40-260. Standard for particulate matter
                                    9 VAC 5-40-320. Standard for visible emissions, referencing 9 VAC 5-40-60 et seq.
The applicable PM standards (in lbs/hour) are dependent on the process weight rate (9 VAC 5-40-260 A) during operation.
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                  B. Monitoring and Recordkeeping

Most units have pollution control devices that ensure compliance with the PM standards in 9 VAC 5-40-260. This can be
readily shown with calculations using AP-42 emission factors, rated capacity, and appropriate control efficiency. Note that
units 276-E3 (Wire Brush Paint Removal) and 276-E3PC (Plasma cutting) are exempt from the PM emission standard of 9
VAC 5-40-260 because the process weight rate are less than 0.05 tons/hr.

Condition V.B.1 requires monthly visible emission evaluations by EPA Method 9 (40 CFR 60 Appendix A) to demonstrate
continuing compliance with visible emission limits.

Recordkeeping is required for visible emission evaluations as well as the throughput of abrasive blasting media and hours of
operation. Records of abrasive throughput and hours of operation for each unit may be used to derive the hourly average
process weight rate and demonstrate compliance with the PM standards using known emission factor and control efficiency.

                  C. Testing

No specific testing is required for the Steel Preparation and Fabrication Operations.


IX.SECONDARY LEAD PROCESSING REQUIREMENTS
                  A. Limitations

The process was permitted to relocate, modify and operate by the 12/16/1981 NSR permit. The permit indicates "11 vertically
fired propane burners and 3 production lines for the melting and fabrication of lead shielding plates". Since the permit does not
provide unit identification numbers, it is difficult to reconcile the units in the 12/16/81 NSR permit with those in the Title V
permit application for Building 4582 that houses the secondary lead operations. Therefore, the equipment list is based on the
best available information including the engineering analysis write-up of the 12/16/81 NSR permit.

The 12/16/81 NSR permit has no specific requirements for the propane burners which have rated heat input capacity ranging
from 0.023 to 2.5 MMBTU/hr. Note that there are also five lead finishing radiant heaters, 0.023 MMBTU/hr each, listed under
Insignificant Activities (Units 4582-E7 through E11). The three production lines are actually two main production lines (4.7
tons/hr per line) and one with limited capacity for training purposes as explained in the engineering analysis write-up of the
12/16/81 NSR permit. They are now identified as units 4582-E1 though E6 (production line, stack 4582-S1), 4582-E12
(production line, stack 4582-S2), and LS-E1 (lead school, stack 4582-S3).

The following Virginia Administrative Codes that have specific emission requirements have been determined to be applicable to
the secondary lead processing emission units:
         9 VAC 5 Chapter 40      Existing Stationary Sources
         9 VAC 5 Chapter 40      Article 18: Emission Standards for Primary and Secondary Metal Operations
                                 9 VAC 5-40-2410. Standard for particulate matter
                                 9 VAC 5-40-2430. Standard for visible emissions, referencing 9 VAC 5-40-60 et seq.
         9 VAC 5 Chapter 50      New and Modified Stationary Sources
                                 9 VAC 5-50-80. Standard for visible emissions


The applicable PM standards based on process weight rate (9 VAC 5-40-2410 A) are less stringent than the permit limits,
hence, they are not included in the Title V permit. The opacity limits for new and modified sources apply as the 12/16/81
permit stated "Part V, Section 5.12- Emission Standards for Visible Emissions" which are equivalent to 9 VAC 5-50-80, more
stringent than those in 9 VAC 5 Chapter 40 Article 18.
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                  B. Monitoring and Recordkeeping

The secondary lead process has baghouse filters as pollution control devices that ensure compliance with the PM permit limits,
based on calculations using AP-42, Table 12.11-2 (1/95) emission factors, rated capacity, and appropriate control efficiency.

Condition VI.B.1 requires weekly visible emission observations followed by, if necessary, visible emission evaluations by EPA
Method 9 (40 CFR 60 Appendix A) to demonstrate continuing compliance with opacity limits.

Recordkeeping is required for visible emissions monitoring as well as the throughput of lead processed. The 12/16/81 NSR
Conditions 6 and 7 also require operator training and certification records, and pollution control equipment maintenance
records.

                  C. Testing

No specific testing is required for the Secondary Lead Processing operations.


X. WOODWORKING OPERATIONS
                  A. Limitations

There are no underlying NSR permit for the Woodworking Operations, however, the following Virginia Administrative Codes
that have specific emission requirements have been determined to be applicable:
         9 VAC 5 Chapter 40        Existing Stationary Sources
         9 VAC 5 Chapter 40        Article 17: Emission Standards for Woodworking Operations
                                   9 VAC 5-40-2270. Standard for particulate matter
                                   9 VAC 5-40-2280. Standard for visible emissions, referencing 9 VAC 5-40-60 et seq.

The woodworking operations are controlled by cyclones, complying with 9 VAC 5-40-2270 A. Particulate emissions are also
limited to 0.05 grains per standard cubic feet of exhaust gas (9 VAC 5-40-2270 B). The facility cuts very large timbers for
shoring as well as smaller pieces for mock-ups that result in larger particles being emitted which are collected by the cyclones.
Visible emissions from the cyclone stacks should be non-existent based on the particle size distribution and the 90% design
control efficiency of the cyclones. No visible emissions would indicate compliance with the PM standards of 9 VAC 5-40-
2270 B in addition to compliance with the applicable existing source opacity standards referred to in 9 VAC 5-40-2280 which
are less stringent.

                  B. Monitoring and Recordkeeping

The permit requires weekly visible emissions observations of the cyclone exhausts. If any visible emissions are observed,
corrective action shall be carried out. Proper operation of the cyclones and a no visible emissions action level on the source
should suffice to ensure compliance with the standard of 0.05 grains of standard cubic foot of exhaust gas (9 VAC 5-40-2270
B) and the less stringent existing source opacity standards.

Monthly inspections for structural integrity of the cyclones are also required.

The permittee shall keep records of the visible emission monitoring and cyclone inspections.

                  C. Testing

No specific testing is required for the Woodworking Operations.
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XI.ELECTROPLATING OPERATIONS
                  A. Limitations

The operations are subject to 40 CFR 63 Subpart N - National Emission Standards for Chromium Emissions from Hard and
Decorative Chromium Electroplating and Chromium Anodizing Tanks, and meet the definition of an existing source in the
subpart. The facility also qualifies as a "small, hard chromium electroplating facility" with a maximum cumulative potential
rectifier capacity less than 60 million amp-hr/year.

There are three chromium electroplating tanks (PLATE-E1 to E3) at the facility which can perform both hard and decorative
chromium plating by changing the plating time to the desired thick or thin layer of chromium, respectively. The applicable
standards for hard chromium electroplating and decorative chromium electroplating are 0.03 mg/dscm and 0.01 mg/dscm,
respectively (40 CFR 63.342 (c)(1)(ii) and 40 CFR 63.342(d)(1), respectively). Note that the initial Title V permit does not list
tank PLATE-E3 because it was not in service at the time, but it is still there and could be operational at any time, hence the
facility wants to keep it on equipment list. On the other hand, as stated in 40 CFR 63.340 (c), "process tanks associated with a
chromium electroplating or chromium anodizing process, but in which neither chromium electroplating nor chromium
anodizing is taking place, are not subject to the provisions of this subpart. Examples of such tanks include, but are not limited
to, rinse tanks, etching tanks, and cleaning tanks. Likewise, tanks that contain a chromium solution, but in which no
electrolytic process occurs, are not subject to this subpart. An example of such a tank is a chrome conversion coating tank
where no electrical current is supplied." Therefore, units PLATE-E4 through PLATE-E22 are not subject to the provisions of
40 CFR 63 Subpart N, and due to their low potential to emit, they qualify as insignificant activities.

                  B. Monitoring and Recordkeeping

The permittee is required to monitor the scrubber once per day for inlet pressure velocity and pressure drop across the
scrubber for comparison with initial compliance test values. There are also required 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).

Operation and Maintenance (O&M) Plan was completed as required by 40 CFR 63.342(f), and is now part of the operating
manual for the electroplating facility.

All monitoring records as well as records of initial compliance tests, maintenance, malfunction and corrective actions, and
operating times for each type of chromium electroplating processes shall be available on site for inspection by the DEQ and
shall be current for the most recent five (5) years. Additionally, 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 shall be kept for the life of the chromium electroplating facility.

                  C. Testing

Initial compliance demonstrations under Subpart N for the electroplating tanks with common add-on control (Zenon packed
tower scrubber 4620-C1) have been completed. The initial compliance date for the decorative chromium electroplating tank
was January 25, 1996, and for the hard chromium electroplating tank, January 25, 1997. Initial performance tests using the
procedures and calculations of 40 CFR 63.344(e)(4) were completed and submitted to EPA and DEQ with the measurements
and calculations used to determine compliance by the applicable due dates. Initial compliance tests indicated the values of inlet
pressure velocity and pressure drop across the scrubber that correlated with compliance with chromium emission limitations in
Table VIII.A. Hence, currently, there are no specific testing requirements other than those required for monitoring.

                  D. Reporting

Semi-annual reports to provide a summary of the documented ongoing compliance status at the electroplating operations are
required in accordance with 40 CFR 63.347(g)(3).
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XII. PAINTING OPERATIONS
The facility is subject to the Shipbuilding and Ship Repair MACT (40 CFR 63 Subpart II) that contains provisions for
controlling volatile organic hazardous air pollutants (VOHAP) from shipbuilding and ship repair coatings.

An NSR permit dated 2/12/86 allowed the construction of an Aluminum Flame Spray Facility. It specifically listed a "paint
spray room which consists of two (2) Binks Dynaprecipitator water wash booths". The current Title V permit application
indicates that the flame spray facility has a total of four (4) spray booths (Units 4701-E10 through E13), each with water wash
curtains. The Aluminum Flame Spray Facility is also part of the Painting Operation Group P-X33 subject to MACT Subpart II.

Another NSR permit dated 7/10/2000, and amended on 2/14/01, allows the construction of a powder coating facility in
Building 205. Besides the powder coating booth (205-PDR), permitted process ovens (205-C1 through C3) and parts-washer
(206-C1) are also addressed here. These natural gas and propane combustion units might have qualified as insignificant
activities due to their small sizes but for the existence of permit conditions. Note that the abrasive blasting units (205-B1 and
B2) listed in this permit are addressed in the Miscellaneous Ac tivities section in accordance with the Title V permit application.

                  A. Limitations

Limitations from MACT Subpart II, 40 CFR 63.783 (a) are included.

Condition 4 of the 2/12/86 permit limits VOC emission from the paint spray room (Building 4701) to 40 lbs/day, 8 lbs/hr, and 7
tons/year, citing BACT (VR 120-05-0403 which is equivalent to 9 VAC 5-50-260).

The 2/14/01 permit limits powder coating throughput, oven fuel throughput, combustion equipment emissions, and opacity for
the powder coating operation (Conditions 9 through 12, respectively). The heat cleaning oven (206-C1) in the powder coating
operation is required by Condition 5 to have an afterburner for emission control. Condition 12 limits visible emissions from the
powder coating operation to 5% opacity. Note that Condition 11 provides emission limits for all the combustion equipment
combined in both lbs/hr and tons/yr. The lbs/hr limit is not included in the Title V permit as it is deemed not necessary.

                  B. Monitoring and Recordkeeping

Applicable monitoring and recordkeeping provisions of 40 CFR 63.783, 63.785, and 63.788 are included.

Condition 5 of the 2/12/86 permit requires daily records of VOC emissions from the flame spray operation. The permittee shall
calculate VOC emissions in pounds per hour and pounds per day once per calendar day, and use such calculations to calculate
annual VOC emissions as the sum of each consecutive 12-month period for Units 4701-E10 through E13.

Continuous monitoring and recording of the temperature of the afterburner of the heat cleaning oven (206-C1C) are included
as in Conditions 7 and 8 of the 2/14/01 permit.

Periodic monitoring to demonstrate compliance with the 5% opacity limit for the burner/oven in the powder coating operation
is added as weekly visible emission observations, followed by corrective action if necessary.

All necessary records on throughputs and monitoring as in Condition 13 of the 2/14/01 permit as well as the visible emissions
observations are included for the powder coating operation.

                  C. Testing
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Reference to test methods of 40 CFR 60 Appendix A is included in accordance with MACT Subpart II, section 40 CFR
63.786.

                  D. Reporting

Applicable reporting requirements of 40 CFR 63.788 are included.




XIII. SPECIALTY SHOPS
                   A. Limitations
Some changes have been made by the facility. The arc gouger (Unit Ref. No. 250-E2) is now listed under Miscellaneous
Activities while the only vapor degreaser at the facility (Unit Ref. No. 64-E5) has been removed. Therefore, the standards of 9
VAC 5-40-3280 B and the control requirements of 9 VAC 5-40-3290 B applicable to vapor degreasers no longer apply. The
cold solvent parts washer operations that remain are still subject to the standards of 9 VAC 5-40-3280 C and the control
requirements of 9 VAC 5-40-3290 C. Disposal of spent solvent is subject to 9 VAC 5-40-3290 D.

The PM emission limits of 9 VAC 5-40-260 are applicable, and vary with the actual process weight rate; the units do not have
true rated capacity:

        E=4.10 P0.67
        where P is the process weight rate in tons/hr and E is the PM emission rate in lbs/hr

The Bayco oven (Unit Ref. No. 64-E3) is subject to NSR permit dated 10/18/1979 but that fact was not recognized in the initial
Title V permit. The NSR permit contains specific PM limit and applicable new source opacity limits of 9 VAC 5-50-80. Other
existing units under this section, on the other hand, is subject to the opacity limits of existing sources (9 VAC 5-40-80)


                  B. Monitoring and Recordkeeping

All PM emitting units have pollution control devices, and units 60-E2 and 114-E1 have recently been outfitted with more
efficient cartridge filters (see Exemption letter dated 10/12/07). Therefore, compliance with the 9 VAC 5-40-260 can be
readily shown with calculations using AP-42 emission factors, appropriate control efficiency, and process weight rate; no
additional monitoring is deemed necessary. Emission tracking by the facility has found emissions less than 3% of the
standards of 9 VAC 5-40-260.

Monthly monitoring of opacity by visible emission observations is required. If opacity is observed, corrective action has to be
carried out. If opacity persists, visible emission evaluations by EPA Method 9 has to be performed to determine compliance
with the opacity limits.

Quarterly inspections of the parts washers ensure compliance with the emission control requirements of 9 VAC 5-40-3290 C.

Records of opacity monitoring, parts washer inspections, and waste solvent disposals shall be available on site for inspection
by the DEQ and shall be current for the most recent five (5) years.

XIV. MISCELLANEOUS ACTIVITIES
Note that the blasting units (Unit Ref. No. 205-B1 and B2) of the powder coating operation are included in this section even
though the powder coating booth (Unit Ref. No. 205-PDR) is included under Painting Operations.
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                   A. Limitations

Conditions from the 9/02/94 NSR for the arc gouger are included, including throughput limits and 5% opacity limit. The
abrasive blasting units (250-B1 and B2) of the powder coating operation are subject to the same opacity limit in accordance
with Condition 12 of the 2/14/01 NSR permit. Other units are subject to the opacity limits for either existing sources (9 VAC
5-40-80) or new sources (9 VAC 5-50-80); the latter are those that are newly installed or modified but exempt from permitting
requirements.

The PM emission limits based on process weight rate in accordance with 9 VAC 5-40-260 apply:

                   0.67
        E=4.10 P          where P is the process weight rate in tons/hour and E is the PM emission rate in lbs/hr

Requirements by Reference to MACT Subpart GGGGG for the remediation activities at the facility are included here.

                   B. Monitoring and Recordkeeping

The pressure drop monitoring device for the arc gouger (250-E2) is required in 9/02/94 NSR. Weekly observations of the
pressure drop and monthly visible emissions evaluations by EPA Method 9 are added as periodic monitoring.

The weekly visible emission observations for the abrasive blast units (205-B1 and B2) of the powder coating operation are also
required to demonstrate compliance with the 5% opacity limits in Condition 12 of 2/14/01 NSR Permit. For units other than
the arc gouger (250-E2) and the abrasive blast units (205-B1 and B2), monthly visible emission observations are deemed
sufficient to demonstrate compliance with the opacity limits in 9 VAC 5-40-80 and 9 VAC 5-50-80. Note that units 5-E2, 50-
E1, 4730-NB (North Blast Room), and 4730-SB (South Blast Room) were grouped with the Steel Preparation and Fabrication
Operations in the original Title V permit where monthly Method 9 was required, however, their results had shown no opacity
due to better PM emission control device.

All point emission sources of PM have pollution control devices. Therefore, compliance with the 9 VAC 5-40-260 can be
readily shown with calculations using AP-42 emission factors, appropriate control efficiency, and process weight rate; no
additional monitoring is deemed necessary. Historically, facility's quantified emissions for those units with controls have been
found to be below 5% of the limits.

Records of arc-gouger throughput, pressure drop and opacity monitoring shall be kept available on site for inspection by the
DEQ and shall be current for the most recent five (5) years.

Monitoring and recordkeeping requirements to qualify for exemption from other requirements of the Site Remediation MACT
are included.


XV. GENERAL CONDITIONS
The permit contains general conditions required by 40 CFR Part 70 and 9 VAC 5-80-110 that apply to all Federal-operating
permitted sources. These include requirements for submitting semi-annual monitoring reports and an annual compliance
certification report. The permit also requires notification of deviations from permit requirements or any excess emissions.

        1. Comments on General Conditions
            a.   Condition B. Permit Expiration
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This condition refers to the Board taking action on a permit application. The Board is the State Air Pollution Control Board.
                                                                                                       §             §
The authority to take action on permit application(s) has been delegated to the Regions as allowed by ? 2.2-604 and ? 10.1-1185
of the Code of Virginia, and the “Department of Environmental Quality Agency Policy Statement No. 3-2006”.

This general condition cites the Article below:
Article 1 (9 VAC 5-80-50 et seq.), Part II of 9 VAC 5 Chapter 80. Federal Operating Permits for Stationary Sources

This general condition cites the sections that follow:
9 VAC 5-80-80. Application
9 VAC 5-80-140. Permit Shield
9 VAC 5-80-150. Action on Permit Applications


             b. Condition F. Failure/Malfunction Reporting

Section 9 VAC 5-20-180 requires malfunction and excess emission reporting within four hours of discovery. Section 9 VAC
5-80-250 of the Title V regulations also requires malfunction reporting; however, reporting is required within two days.
Section 9 VAC 5-20-180 is from the general regulations. All affected facilities are subject to section 9 VAC 5-20-180 including
Title V facilities. Section 9 VAC 5-80-250 is from the Title V regulations. Title V facilities are subject to both sections. A
facility may make a single report that meets the requirements of 9 VAC 5-20-180 and 9 VAC 5-80-250. The report must be
made within four daytime business hours of discovery of the malfunction.

In order for emission units to be relieved from the requirement to make a written report in 14 days the emission units must
have continuous monitors meeting the requirements of 9 VAC 5-50-410 or 9 VAC 5-40-41. Periodic reports are then
submitted for those continuous monitoring systems (CMS). Note that quarterly reports are required for the NOx CEMS of
boilers TS-E1 and E2 and semi-annual reports are required for other CMS at the facility because only the NOx CEMS provides
direct compliance demonstration.

This general condition cites the sections that follow:

9 VAC 5-40-41.     Emissions Monitoring Procedures for Existing Sources
9 VAC 5-40-50.     Notification, Records and Reporting
9 VAC 5-50-50.     Notification, Records and Reporting

This general condition contains a citation from the Code of Federal Regulations as follows:
40 CFR 60.13 (h). Monitoring Requirements.


             c. Condition J. Permit Modification

This general condition cites the sections that follow:
9 VAC 5-80-50. Applicability, Federal Operating Permit for Stationary Sources
9 VAC 5-80-190. Changes to Permits.
9 VAC 5-80-260. Enforcement.
9 VAC 5-80-1100. Applicability, Permits for New and Modified Stationary Sources
9 VAC 5-80-1790. Applicability, Permits for Major Stationary Sources and Modifications Located in Prevention of Significant
Deterioration Areas
9 VAC 5-80-2000. Applicability, Permits for Major Stationary Sources and Major Modifications Locating in Nonattainment
Areas


             d. Condition U. Malfunction as an Affirmative Defense
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The regulations contain two reporting requirements for malfunctions that coincide. The reporting requirements are listed in
sections 9 VAC 5-80-250 and 9 VAC 5-20-180. The malfunction requirements are listed in General Condition U and General
Condition F. For further explanation see the comments on general condition F.

This general condition cites the sections that follow:
9 VAC 5-20-180. Facility and Control Equipment Maintenance or Malfunction
9 VAC 5-80-110. Permit Content


             e.   Condition Y. Asbestos Requirements

The Virginia Department of Labor and Industry under Section 40.1-51.20 of the Code of Virginia also holds authority to
enforce 40 CFR 61 Subpart M, National Emission Standards for Asbestos.

This general condition contains a citation from the Code of Federal Regulations that follow:
40 CFR 61.145, NESHAP Subpart M. National Emissions Standards for Asbestos as it applies to demolition and renovation.
40 CFR 61.148, NESHAP Subpart M. National Emissions Standards for Asbestos as it applies to insulating materials.
40 CFR 61.150, NESHAP Subpart M. National Emissions Standards for Asbestos as it applies to waste disposal.

This general condition cites the regulatory sections that follow:
9 VAC 5-60-70. Designated Emissions Standards
9 VAC 5-80-110. Permit Content
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XVI. STATE ONLY APPLICABLE REQUIREMENTS
The following Virginia Administrative Codes have specific requirements only enforceable by the State and have been identified
as applicable by the applicant:

    9 VAC 5-40-130 et seq. (Rule 4-2), and 9 VAC 5-50-130 et seq. (Rule 5-2), Odorous Emissions.

    9 VAC 5-60-200 et seq. (Rule 6-4), and 9 VAC 5-60-300 et seq. (Rule 6-5), Toxics Emissions.


XVII. FUTURE APPLICABLE REQUIREMENTS
The boilers TS-E1 and TS-E2 at the facility were subject to the boiler MACT (40 CFR 63 Subpart DDDDD) before it was
vacated. The facility has submitted Part 1 Title V Application pursuant to Clean Air Act Section 112 (j) provisions (case- by-
case MACT) on March 12, 2009, and will submit Part 2 when requested by VA DEQ. At this time, EPA is scheduled to re-
propose the boiler MACT by July 15, 2009.
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XVIII.           INAPPLICABLE REQUIREMENTS
The following requirements 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             VOL storage tanks, capacity
                                    Standard (NSPS) Requirements       20,000 to < 40,000 gal with
                                    for Volatile Organic Liquid        maximum true vapor pressure
                                    Storage Vessels for Which          >=15 kPa (2.16 psi), and capacity
                                    Construction, Reconstruction, or   >= 40,000 gal with maximum true
                                    Modification commenced after       vapor pressure >=3.5 kPa (0.5 psi).
                                    July 23, 1984                       Facility's tanks with the cited
                                                                       capacities have maximum true
                                                                       vapor pressure less than the cited
                                                                       thresholds.
     9 VAC 5-40-3410 et seq.        Emission Standards For Volatile    Non-petroleum liquid storage
     (Rule 4-25)                    Organic Compound Storage and       tanks, 40,000 gal capacity or
                                    Transfer Operations                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    Solvent cleaning machines
                                    Halogenated Solvent Cleaning       containing certain halogenated
                                                                       solvents which are not used at
                                                                       the facility.
     40 CFR 63 Subpart X            National Emission Standards for    Secondary lead smelter using
                                    Hazardous Air Pollutants from      lead-bearing scrap metals.
                                    Secondary Lead Smelting            Facility uses pure lead ingots.
     40 CFR 60 Subpart IIII         Standards of Performance for       New, modified, and reconstructed
                                    Stationary Compression Ignition    ICE meeting certain size and
                                    Internal Combustion Engines (ICE) manufacture date in the rule.
     40 CFR 63 Subpart ZZZZ         National Emission Standards For    RICE at major HAP sources
                                    Hazardous Air Pollutants for       meeting the size and type in the
                                    Stationary Reciprocating Internal  rule.
                                    Combustion Engines (RICE)
     40 CFR 60 Subpart JJJJ         Standards of Performance for       New, modified, and reconstructed
                                    Stationary Spark Ignition Internal SI ICE ordered after June 12, 2006.
                                    Combustion Engines (SI ICE)

        The startup, shut down, and malfunction opacity exclusion listed in 9 VAC 5-40-20 A 4 cannot be included in any
        Title V permit. This portion of the regulation is not part of the federally approved state implementation plan. The
        opacity standard applies to existing sources at all times including startup, shutdown, and malfunction. Opacity
        exceedances during malfunction can be affirmatively defended provided all requirements of the affirmative defense
        section of this permit are met. Opacity exceedances during startup and shut down will be reviewed with enforcement
        discretion using the requirements of 9 VAC 5-40-20 E, which state that "At all times, including periods of startup,
        shutdown, 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."
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XIX. INSIGNIFICANT EMISSION UNITS
The insignificant emission units are presumed to be in compliance with all requirements of the 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. Insignificant emission units include the following:

Emission       Emission Unit                                      Pollutant(s) Emitted    Rated Capacity
                                              Citation
Unit No.       Description                                        (9 VAC 5-80-720 B)      (9 VAC 5-80-720 C)
               Shop- Perkins Diesel
   103-E1                                      9 VAC 5-80-720 C            NA                    40 Hp
               Generator
               Tool Room & Office- Perkins
   160-E1                                      9 VAC 5-80-720 C            NA                    40 Hp
               Diesel Generator
               Utility Substation
   1744-E3                                     9 VAC 5-80-720 C            NA                    80.4 Hp
               Emergency Generator
   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
               Natural Gas-Fired Boiler,
   1796-E1                                     9 VAC 5-80-720 C            NA                2.0 MMBTU/hr
               #42806, 2006
               Hull Outfitting & Electrical
    23-E1      Shops - Perkins Diesel          9 VAC 5-80-720 C            NA                    40 Hp
               Generator
               Consolidated Storage -
    2-E1       Perkins Diesel Emergency        9 VAC 5-80-720 C            NA                    40 Hp
               Generator
               Radcon Control Firehouse -
   4632-E1     Caterpillar Diesel Emergency    9 VAC 5-80-720 C            NA                    324 Hp
               Generator
               MOF, South - Cummins
   4677-E2                                     9 VAC 5-80-720 C            NA                    80 Hp
               Diesel Emergency Generator
               MOF, North - Cummins
   4677-E3                                     9 VAC 5-80-720 C            NA                    67 Hp
               Diesel Emergency Generator
               MOF, East - Detroit Diesel
   4677-E4                                     9 VAC 5-80-720 C            NA                    47 Hp
               Emergency Generator
   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
               Office - Perkins Diesel
   520-E1                                      9 VAC 5-80-720 C            NA                    67 Hp
               Emergency Generator
               Computer & Materials
   521-E1      Support - Cummins Diesel        9 VAC 5-80-720 C            NA                    603 Hp
               Emergency Generator
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Emission      Emission Unit                                      Pollutant(s) Emitted    Rated Capacity
                                             Citation
Unit No.      Description                                        (9 VAC 5-80-720 B)      (9 VAC 5-80-720 C)
              Perkins Diesel Emergency
   86-E1                                      9 VAC 5-80-720 C            NA                    235 Hp
              Generator
 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
              Fire Dept. #1-port -
  GEN-E11     Caterpillar Diesel Emergency    9 VAC 5-80-720 C            NA                    268 Hp
              Generator
              Fire Dept. #2-port -
  GEN-E12     Caterpillar Diesel Emergency    9 VAC 5-80-720 C            NA                    268 Hp
              Generator
  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
              Communications Tower -
  GEN-E17                                     9 VAC 5-80-720 C            NA                    282 Hp
              Detroit Diesel Generator
              Portable - Detroit Diesel
  GEN-E18                                     9 VAC 5-80-720 C            NA                    282 Hp
              Generator
              Scrap Yard Fuel Storage
  GEN-E19     Facility - Detroit Diesel       9 VAC 5-80-720 C            NA                    46.9 Hp
              Generator
              Ring Module Shop - Generac
  GEN-E20                                     9 VAC 5-80-720 C            NA                    40.2 Hp
              Diesel Generator Set
  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
  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
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Emission     Emission Unit                                      Pollutant(s) Emitted    Rated Capacity
                                            Citation
Unit No.     Description                                        (9 VAC 5-80-720 B)      (9 VAC 5-80-720 C)
  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
             Cummins/Onan Diesel
  GEN-E6                                     9 VAC 5-80-720 C            NA                    402 Hp
             Generator Set
  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
             Cummins Diesel Emergency
  PIER2-E1                                   9 VAC 5-80-720 C            NA                    469 Hp
             Generator
  GEN-E34    Detroit Diesel Generator        9 VAC 5-80-720 C            NA                    47 Hp
             Portable Generators Rated at
  GENP-E1    equal to or greater than 14     9 VAC 5-80-720 C            NA                    <12 Hp
             kW
             Cummins 6” Portable
 PUMP-E1                                     9 VAC 5-80-720 C            NA                    95.2 Hp
             Emergency Diesel Pump
             Cummins 6” Portable
 PUMP-E2                                     9 VAC 5-80-720 C            NA                    95.2 Hp
             Emergency Diesel Pump
             Heat Treating Furnace 3,
  550-E15                                    9 VAC 5-80-720 C            NA                1.3 MMBTU/hr
             #39386
   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
             Buffalo Forge-Space Heating
   274-E4    Flat Prep. Inspection,          9 VAC 5-80-720 C            NA               1.88 MMBTU/hr
             propane
             Buffalo Forge-Space Heating
   274-E5    Flat Prep. Inspection,          9 VAC 5-80-720 C            NA               0.56 MMBTU/hr
             propane
             Buffalo Forge-Space Heating
   274-E6    Flat Prep. Inspection,          9 VAC 5-80-720 C            NA               0.56 MMBTU/hr
             propane
             Buffalo Forge-Space Heating
   274-E7    Flat Prep. Inspection,          9 VAC 5-80-720 C            NA               1.88 MMBTU/hr
             propane

   274-E8    Buffalo Forge-Space Heating     9 VAC 5-80-720 C            NA               0.56 MMBTU/hr
             Flat Prep. Inspection,
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Emission     Emission Unit                                        Pollutant(s) Emitted    Rated Capacity
                                              Citation
Unit No.     Description                                          (9 VAC 5-80-720 B)      (9 VAC 5-80-720 C)
             propane
             Wing Heat-Space Heating
   274-E9    Flat Prep. Inspection,            9 VAC 5-80-720 C            NA                0.4 MMBTU/hr
             propane
             Wing Heat-Space Heating
  274-E10    Flat Prep. Inspection,            9 VAC 5-80-720 C            NA                0.4 MMBTU/hr
             propane
             Wing Heat-Space Heating
  274-E11    Flat Prep. Inspection,            9 VAC 5-80-720 C            NA                0.4 MMBTU/hr
             propane
   275-E1    Thermal Dryer, propane            9 VAC 5-80-720 C            NA                3.2 MMBTU/hr
             Buffalo Forge - Shape Prep,
   275-E2                                      9 VAC 5-80-720 C            NA               1.88 MMBTU/hr
             propane
             Buffalo Forge - Shape Prep,
   275-E3                                      9 VAC 5-80-720 C            NA               1.88 MMBTU/hr
             propane
   276-E5    Oven, propane                     9 VAC 5-80-720 C            NA               2.58 MMBTU/hr
             Electrolux Paint Dryer - Plate
  1746-E2                                      9 VAC 5-80-720 C            NA               8.33 MMBTU/hr
             Preparation, propane
             Electrolux Paint Dryer - Plate
  1746-E3                                      9 VAC 5-80-720 C            NA               8.33 MMBTU/hr
             Preparation, propane
             Lead Finishing Radiant
  4582-E7                                      9 VAC 5-80-720 C            NA               0.023 MMBTU/hr
             Heater
             Lead Finishing Radiant
  4582-E8                                      9 VAC 5-80-720 C            NA               0.023 MMBTU/hr
             Heater
             Lead Finishing Radiant
  4582-E9                                      9 VAC 5-80-720 C            NA               0.023 MMBTU/hr
             Heater
             Lead Finishing Radiant
  4582-E10                                     9 VAC 5-80-720 C            NA               0.023 MMBTU/hr
             Heater
             Lead Finishing Radiant
  4582-E11                                     9 VAC 5-80-720 C            NA               0.023 MMBTU/hr
             Heater
  4619-E1    Sludge dryer - electric           9 VAC 5-80-720 C            NA                     NA
             Super heater - Ship Repair
   17-E2                                       9 VAC 5-80-720 C            NA                0.6 MMBTU/hr
             Machine Shop
             Curing Oven - Main
   60-E4                                       9 VAC 5-80-720 C            NA               0.175 MMBTU/hr
             Machine Shop (w/ filter)
   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            9 VAC 5-80-720 C            NA                4.2 MMBTU/hr
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Emission     Emission Unit                                     Pollutant(s) Emitted    Rated Capacity
                                           Citation
Unit No.     Description                                       (9 VAC 5-80-720 B)      (9 VAC 5-80-720 C)
             Line
                                                                Metallic oxides and
 PLATE-E4    Chromium strip tank            9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E5    Electrocleaner tank - Cd       9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E6    Electrocleaner tank - Cu/Ni    9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E7    Electrocleaner tank - Cr/Ni    9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E8    Electrocleaner tank - Cr       9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E9    Electrocleaner tank - Cr/Ni    9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E10   Chromic acid tank              9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E11   Cadmium plating tank           9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E12   Barrel cadmium plating         9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E13   Zinc plating tank              9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E14   Barrel zinc plating            9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E15   Cyanide copper tank            9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E16   Nickel plating tank            9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
                                                                Metallic oxides and
 PLATE-E17   Nickel strip tank              9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                   compounds
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Emission        Emission Unit                                        Pollutant(s) Emitted    Rated Capacity
                                                 Citation
Unit No.        Description                                          (9 VAC 5-80-720 B)      (9 VAC 5-80-720 C)
                                                                      Metallic oxides and
 PLATE-E18      Dull nickel plating tank          9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                         compounds
                                                                      Metallic oxides and
 PLATE-E19      Lead plating tank                 9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                         compounds
                                                                      Metallic oxides and
 PLATE-E20      Silver strike tank                9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                         compounds
                                                                      Metallic oxides and
 PLATE-E21      Silver plating tank               9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                         compounds
                                                                      Metallic oxides and
 PLATE-E22      Acid copper plating tank          9 VAC 5-80-720 B    non-HAP inorganic              NA
                                                                         compounds
    29-PT       Pickling Tank, 6,400 gal          9 VAC 5-80-720 B           H2SO4                   NA
                Four Pickling Tanks, each
   161-PT                                         9 VAC 5-80-720 B           H2SO4                   NA
                3,240 gal
   SY-E1        Natural gas-fired boiler, Rite    9 VAC 5-80-720 C            NA               0.48 MMBTU/hr
                Natural gas-fired boiler,
   4768-E1                                        9 VAC 5-80-720 C            NA                2.8 MMBTU/hr
                Burnham
                Natural gas-fired boiler,
   4768-E2                                        9 VAC 5-80-720 C            NA                2.8 MMBTU/hr
                Burnham
                Propane-fired test boiler,
    17-E1                                         9 VAC 5-80-720 C            NA               2.73 MMBTU/hr
                Singer Vapor
                Natural gas-fired boiler,
   521-E1                                         9 VAC 5-80-720 C            NA                2.0 MMBTU/hr
                Aerco
                Natural gas-fired boiler,
   521-E2                                         9 VAC 5-80-720 C            NA                2.0 MMBTU/hr
                Aerco
                Natural gas-fired boiler,
   521-E3                                         9 VAC 5-80-720 C            NA                2.0 MMBTU/hr
                Aerco
                Natural gas-fired boiler,
   521-E4                                         9 VAC 5-80-720 C            NA                2.0 MMBTU/hr
                Aerco
                Natural gas-fired boiler,
   521-E5                                         9 VAC 5-80-720 C            NA                2.0 MMBTU/hr
                Aerco
                Natural gas-fired boiler,
   521-E6                                         9 VAC 5-80-720 C            NA                2.0 MMBTU/hr
                Aerco
                Natural gas-fired boiler,
   521-E7                                         9 VAC 5-80-720 C            NA                2.0 MMBTU/hr
                Aerco

 5664 / 4677-   Special Hull Treatment            9 VAC 5-80-720 B           VOC                     NA
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Emission    Emission Unit                                      Pollutant(s) Emitted     Rated Capacity
                                           Citation
Unit No.    Description                                        (9 VAC 5-80-720 B)       (9 VAC 5-80-720 C)
     SHT
  276-CNC   CNC Cutting Machine             9 VAC 5-80-720 B            PM                      NA
            Carrier Modular Assembly
1865-CMAF                                   9 VAC 5-80-720 B            PM                      NA
            Facility – Platen #21
  1865-
            10 Natural gas-fired space
 CMAFB1-                                    9 VAC 5-80-720 C            NA               2.4 MMBTU/hr each
            heaters at CMAF
   B10
            LA-4123 PVC Seam
   907-E1                                   9 VAC 5-80-720 B        MEK, VOC                    NA
            Adhesive Operation
            Nitrogen/Oxygen Cylinder
   518-E1                                   9 VAC 5-80-720 B         TCE, VOC                   NA
            Purge & Clean Operation
            Saw for Calcium Silicate
  1833-E1                                   9 VAC 5-80-720 B   Vents Inside Building            NA
            Insulation, 1.5 Hp
            Portable ALC Sandy Jet
  4698-E1                                   9 VAC 5-80-720 B            PM                      NA
            Pressure Blaster
            Carrier Modular Outfitting
1872-CMOF                                   9 VAC 5-80-720 B            PM                      NA
            Facility
    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
   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
            Recycled Oil Tank, 19,827
   A301                                     9 VAC 5-80-720 B           VOC                      NA
            gallons
                                                                                       Northrop Grumman Shipbuilding, Inc.
                                                                                                                TRO-60153
                                                                                        Statement of Legal and Factual Basis
                                                                                                               June 1, 2009
                                                                                                                    Page 46

Emission     Emission Unit                                      Pollutant(s) Emitted    Rated Capacity
                                            Citation
Unit No.     Description                                        (9 VAC 5-80-720 B)      (9 VAC 5-80-720 C)
             Recycled Oil Tank, 19,827
   A302                                      9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Waste Tank, 60,000
   A401                                      9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Waste Tank, 60,000
   A402                                      9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Waste Tank, 8,310
   A403                                      9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Wastewater Tank,
   A405                                      9 VAC 5-80-720 B           VOC                     NA
             25,000 gallons
             Oily Wastewater Tank, 1,000
   A407                                      9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Wastewater Tank, 1,000
   A408                                      9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Wastewater Tank, 1,000
   A409                                      9 VAC 5-80-720 B           VOC                     NA
             gallons
   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
             Oily Wastewater Tank, 6,000
   A414                                      9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Wastewater Tank, 2,000
   A415                                      9 VAC 5-80-720 B           VOC                     NA
             gallons
   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
             Oily Waste Tank, 910
 A601-A635                                   9 VAC 5-80-720 B           VOC                     NA
             gallons
    V706     Diesel Tank, 500 gallons        9 VAC 5-80-720 B           VOC                     NA
             Oily Waste Tank, 10,000
    V707                                     9 VAC 5-80-720 B           VOC                     NA
             gallons
    U232     Diesel Tank, 1,000 gallons      9 VAC 5-80-720 B           VOC                     NA
    U305     Gasoline Tank, 6,000 gallons    9 VAC 5-80-720 B           VOC                     NA
             No. 6 Oil Tank, 500,000
    U503                                     9 VAC 5-80-720 B           VOC                     NA
             gallons
    U504     No. 6 Oil Tank, 171,000         9 VAC 5-80-720 B           VOC                     NA
                                                                                       Northrop Grumman Shipbuilding, Inc.
                                                                                                                TRO-60153
                                                                                        Statement of Legal and Factual Basis
                                                                                                               June 1, 2009
                                                                                                                    Page 47

Emission     Emission Unit                                      Pollutant(s) Emitted    Rated Capacity
                                            Citation
Unit No.     Description                                        (9 VAC 5-80-720 B)      (9 VAC 5-80-720 C)
             gallons
             No. 6 Oil Tank, 171,000
    U505                                     9 VAC 5-80-720 B           VOC                     NA
             gallons
             No. 6 Oil Tank, 10,000
    U508                                     9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Water Tank, 48,000
    U511                                     9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Water Tank, 20,000
    U512                                     9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Water Tank, 20,000
    U513                                     9 VAC 5-80-720 B           VOC                     NA
             gallons
             Oily Water Tank, 30,000
    U514                                     9 VAC 5-80-720 B           VOC                     NA
             gallons
    U517     Oily Water Tank                 9 VAC 5-80-720 C            NA                  550 gallons
             Oily Water Tank, 3,918
    U518                                     9 VAC 5-80-720 B           VOC                 3,918 gallons
             gallons
             Oily Water Tank, 3,918
    U519                                     9 VAC 5-80-720 B           VOC                 3,918 gallons
             gallons
             Car Wash Tank, 8,000
    U600                                     9 VAC 5-80-720 B           VOC                 8,000 gallons
             gallons
             Aqueous Cleaning
 SG401-424   Chemicals, 18,000 gallons       9 VAC 5-80-720 B           none                    NA
             each
   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
             Aqueous Cleaning
 SG429-431   Chemicals, 6,000 gallons        9 VAC 5-80-720 B           none                    NA
             each
             Aqueous Cleaning
   SG432                                     9 VAC 5-80-720 B           none                    NA
             Chemicals, 9,000 gallons
             Aqueous Cleaning
 SG433-434   Chemicals, 18,000 gallons       9 VAC 5-80-720 B           none                    NA
             each
             Aqueous Cleaning
 SG435-438   Chemicals, 4,000 gallons        9 VAC 5-80-720 B           none                    NA
             each
 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
                                                                                            Northrop Grumman Shipbuilding, Inc.
                                                                                                                     TRO-60153
                                                                                             Statement of Legal and Factual Basis
                                                                                                                    June 1, 2009
                                                                                                                         Page 48

Emission          Emission Unit                                      Pollutant(s) Emitted    Rated Capacity
                                                Citation
Unit No.          Description                                        (9 VAC 5-80-720 B)      (9 VAC 5-80-720 C)
                  Phosphate Water, 18,000
  SG443-446                                      9 VAC 5-80-720 B            none                     NA
                  gallons each
                  Portable PO4 Water, 18,000
  SG447-449                                      9 VAC 5-80-720 B            none                     NA
                  gallons each
                  DI/DEOX water/chilled
    SG452                                        9 VAC 5-80-720 B            none                     NA
                  water,22,500 gal
                  DI/DEOX water,18,000
  SG453-455                                      9 VAC 5-80-720 B            none                     NA
                  gallons each
                  Underfloor Collection, 1000
    SG456                                        9 VAC 5-80-720 B            none                     NA
                  gallons
                  Dead Leg Collection, 250
    SG457                                        9 VAC 5-80-720 B            none                     NA
                  gallons
    SG458         Bleed Tank, 18,000 gallons     9 VAC 5-80-720 B            none                     NA
                  No. 6 Oil Tank, 124,203
    V700                                         9 VAC 5-80-720 B             VOC                     NA
                  gallons
                  No. 6 Oil Tank, 124,203
    V701                                         9 VAC 5-80-720 B             VOC                     NA
                  gallons
                  No. 6 Oil Tank, 93,884
    V702                                         9 VAC 5-80-720 B             VOC                     NA
                  gallons
                  No. 6 Oil Tank, 93,884
    V703                                         9 VAC 5-80-720 B             VOC                     NA
                  gallons
                  No. 6 Oil Tank, 60,373
    V704                                         9 VAC 5-80-720 B             VOC                     NA
                  gallons
                  No. 6 Oil Tank, 60,373
    V705                                         9 VAC 5-80-720 B             VOC                     NA
                  gallons

    1
        The citation criteria for insignificant activities are as follows:
           9 VAC 5-80-720 A - Listed Insignificant Activity, Not Included in Permit Application
           9 VAC 5-80-720 B - Insignificant due to emission levels
           9 VAC 5-80-720 C - Insignificant due to size or production rate


XX.        CONFIDENTIAL INFORMATION
The permittee did not submit a request for confidentiality. All portions of the Title V application are suitable for public review.


XXI. PUBLIC PARTICIPATION
The proposed permit will be place on public notice in the Daily Press from
Thursday, April 16, 2009 to Monday, May 18, 2009.