TECHNICAL SUPPORT DOCUMENT (TSD)
INTRODUCTION
Luke Air Force Base (Luke AFB) is a military training installation, owned and operated by the United Sates Department of Defense, located within Maricopa County, Arizona approximately 9 miles west of downtown Glendale, Arizona on approximately 3,862 acres and employs approximately 8,200 military and non-military personnel. Luke AFB is the largest and only active duty F-16 pilots training base in the world and will soon train United States and Partner F-35A pilots. Luke AFB is a major source for two criteria pollutants, NOx and VOC emissions, but not for Hazardous Air Pollutants (HAP). It is classified as Standard Industrial Code (SIC) 9711, National Security.
The Phoenix metropolitan area has been designated as a serious non-attainment area for PM10 National Ambient Air Quality Standard and as a moderate non-attainment area for the 2008 8-hour Ozone National Ambient Air Quality Standard.
This Technical Support Document (TSD) is intended to provide additional information associated with the technical and regulatory evaluation of the Application 412754 for Renewal <IP_ADDRESS> of Permit V97017. This TSD is not a part of the Permit and is not legally enforceable.
FACILITY DESCRIPTION
Luke AFB is a large multi-faceted installation which is comparable in size and function to a small city.  Operations at Luke AFB include training of military personnel, support activities for housing and feeding personnel, and maintenance and support of military equipment and operations.  Specifically, the base has operations including, but not limited to: retail markets, hospital and dental clinics, public works, warehouse facilities, utilities, recreational facilities, an airfield, and maintenance operations.  It is important to note that Luke AFB has several tenant operations.  With the exception of the Army Air Force Exchange Service (AAFES) service station and the auto hobby paint booth and woodworking shop, emissions from tenant operations are regulated as a part of Luke AFB operations even though they are not under "common control".  The AAFES service station and auto hobby paint booth are regulated separately and are not discussed further in this renewal application.
Sources of air pollutants include external combustion equipment used for heating base facilities; internal combustion equipment used for emergency power; use of volatile organic compounds VOC containing materials such as solvents, paints, and adhesives for maintenance of vehicles and aircraft, sign painting, woodworking facilities for construction of signs and furniture, surface coating operations, and gasoline, diesel, and Jet-A storage tanks used for fueling motor vehicles, aircraft and miscellaneous facility equipment.
RENEWAL DESCRIPTION
All prior revisions are incorporated in this renewal permit, which does not constitute a physical change or change in the method of operation of the facility. Additionally, there were a number of County Rules revised during the course of preparing this renewal permit. Those revised Rules have been included in this renewal permit.
4.	APPLICABLE REQUIREMENTS
The application included a listing and discussion of all the regulatory requirements applicable to the source, which can be viewed in the following embedded icon:

5.	EMISSIONS:
A. 	FACILITY WIDE EMISSION:
Generating operations at the facility are conducted in many different buildings/locations on the base, all as identified in Appendix A and the Equipment List of the renewal application. In the following paragraphs, they include, (B) abrasive blasting, (C) external combustion sources such as: boilers and water heaters, spray paint booth dryers, and a bake-off oven, (D) fire fighter training-part of open outdoor burning, (E) fuel cell maintenance, (F) fuel dispensing-gasoline, (G) fuel loading-Jet A & diesel, (H) fuel storage in above ground storage tanks such as: Jet-A, diesel storage tanks, and gasoline storage tanks, (I) jet engine test cells, (J) miscellaneous chemicals and surface coating, (K) solvent cleaning, (L) internal combustion engines, (M) woodworking and (N) miscellaneous discussion of water cooling towers, waste water treatment plant and open outdoor burning.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List. A summary of emissions by process is presented in the icon below under the SP Form tab. For purposes of these calculations PM2.5 emissions are assumed to equal PM10 emissions.

Following in Tables A1 and A2 are Potential to Emit Summaries of criteria pollutants and hazardous air pollutants (HAP), which represent the total emissions from all the various sources of emissions facility wide. As the values in the following tables indicate the facility is a major source of NOx and VOC as criteria pollutants, but is not a major source of HAP either as a single HAP or as a combination of HAP.
Table A1 Facility Wide Emissions of Criteria Pollutants

                                  Pollutants
                                   Emissions
                                      CO
                                      NOx
                                      SOx
                                      VOC
                                     PM10
                                     PM2.5
                                   tons/year
                                   lbs/year
                                     78.2
                                    156,365
                                     163.2
                                    326,242
                                      5.2
                                    10,420
                                     114.5
                                    228,916
                                     12.3
                                    24,641
                                     12.3
                                    24,641
Only total HAP are shown in the Table below but in the Appendix A Calculations the HAP are also speciated.
Table A2 Facility Wide Emissions of Hazardous Air Pollutants (HAP)
                            Total HAPs (tons/year)
                                      8.0
                             Total HAPs (lbs/year)
                                    15,999

In the following paragraphs are brief explanatory discussions and tabular illustrations of each of the various operations that contribute to the facility wide emissions. These are presented in the same order as they were presented in the application.
B.	ABRASIVE BLASTING:
Emissions Source Description: Abrasive blasting operations involve the use of a hard material such as sand, plastic beads, or glass beads to remove old paint and/or corrosion from equipment.  A high pressure gun is used to blast the abrasive material at the equipment being stripped/cleaned.  Depending on the size of the equipment, blasting is performed in either a small enclosed cabinet (i.e., glove box), inside a booth, or outdoors.  For indoor blasting, the exhausts from blasting operations are ventilated to a control system consisting of a fabric filter.  The primary pollutants of interest are PM10, PM2.5, and HAP within the particulate.
Luke AFB has one walk-in abrasive blasting booth in Building 907 which vents to atmosphere.  The remaining units are small glove-box blasters (modular, self-contained, abrasive blasting cabinets) that exhaust into the work space, and are considered an insignificant source in accordance with MCAPCR Appendix D ["Hand-held or manually operated equipment used for buffing, polishing, carving, cutting, drilling, machining, routing, sanding, sawing, surface grinding, or turning of ceramic art work, precision parts, leather, metals, plastics, fiberboard, masonry, carbon, glass, or wood."].
Emissions Calculations: Maximum emissions from abrasive blasting have been estimated by multiplying the amount of blast media consumed by the appropriate emission factor, as shown in the equation below.
      EPol = Q x 1/1,000 x EFPol
      Where,
      EPOL = Emissions of a particular pollutant (lb/yr);
      Q = Annual blast media consumed (lb/yr); and
      EFPOL = Emissions factor (lb/10[3] lb of blast media used).
Maximum particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM10) emissions were estimated based on the maximum blasting material which could be used and the emission factor for controlled garnet blasting obtained Table 2-1 of the Air Emissions Guide for Stationary Sources, AFCEC, October 2014 (AEI Guide) (0.59 pounds (lb) per thousand pounds (10[3] lb) of PM10 of abrasive material used).  PM and PM2.5 emission were assumed to be equal to PM10 emissions.
HAP emissions were conservatively assumed to be 100% of particulate matter (PM) emissions.  HAP emissions from abrasive blasting are a much smaller percentage of PM emissions and should a more accurate speciation be desired, a chemical analysis of the waste material collected would be required.
Maximum media usage for the unit were determined by taking the media usage in 2007, which Luke AFB has set as the baseline year based on  knowledge of usual operations, and scaling this number up by 4.21.  The factor of 4.21 is the ratio of the maximum number of hours per year (8,760) to current average actual site operating hours of eight hours per day, five days per week, 52 weeks per year (2,080 hours per year), which conservatively assumes that abrasive blasting at Luke AFB would increase proportionately to base operations.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table B 1 is a Potential to Emit Summary of criteria pollutants and HAP from abrasive blasting sources shown in full display in Appendix A of this TSD under the ABCL tab in the embedded icon cited above.
Table B 1

                                   Emissions
                                  PM10/PM2.5
                                      HAP
                                   tons/year
                                   lbs/year
                                       0
                                     1.74
                                       0
                                     1.74
C.	EXTERNAL COMBUSTION EMISSIONS:
Emissions Source Description: The majority of external combustion sources at Luke AFB include boilers, furnaces, and heaters used for comfort heating and potable water.  Luke AFB also has three spray paint booth dryers which are used in association with the civilian and government vehicle paint booths to provide heated air to dry painted parts, and two bake-off ovens which are used for the removal of baked-on particulate matter from jet engine fuel spray rings.
Emissions from external combustion units occur as a result of the combustion of the fuel burned and include criteria pollutants and a variety of HAPs.  Emissions depend on a variety of factors including the size/type of the combustor, firing configuration, fuel type, control devices used, operating capacity, and whether the system is properly operated/maintained.
The external combustion units at Luke AFB primarily utilize natural gas for fuel, although some units use either propane or LPG for fuel.
Emissions from the burn-off ovens are considered to be solely due to the combustion of natural gas used to fuel the oven, as the jet engine spray rings are pre-cleaned prior to placement in the burn off ovens and the combustion of any debris remaining can be considered negligible per MCAQD guidance (refer to Section 6 of this TSD for additional information on excluded sources and the guidance provided by MCAQD). See also County Rule 100 §200.63 for the definitions of insignificant activities.
Certain external combustion sources (e.g., water heaters <300,000 MMBTU/hr) at Luke AFB are considered an insignificant source in accordance with MCAPCR Appendix D ["All natural gas and/or liquefied petroleum gas-fired pieces of equipment over 300,000 BTU per hour, only if the input capacities added together are less than 2,000,000 BTU per hour, the emissions come from fuel burning, and the equipment is used solely for heating buildings for personal comfort or for producing hot water for personal use."].  Refer to Section 6 of this TSD and see also County Rule 100 §200.63 for additional information on insignificant sources.  All external combustion units, including those that may be insignificant, have been included in maximum emissions calculations to allow for a conservative estimate.
Emissions Calculations: Emissions from external combustion units were estimated by multiplying the amount of fuel combusted by the appropriate emission factor, as shown in the equation below.
      EPOL = FC x EF
      Where,
      EPOL = Emissions of a particular pollutant (lb/yr);
      FC = Quantity of fuel consumed per year (MMBtu/yr for natural gas); and
      EF = Emission factor (lb/MMBtu for natural gas).
Calculations were completed using emission factors from AP-42, Section 1.4, Natural Gas Combustion (July 1998).  Emission factors were converted from lb/10[6] ft3 to lb/MMBtu using a heating value of 1,020 Btu/ft[3], taken from AP-42, Section 1.4, Natural Gas Combustion (July 1998).  Emissions for propane and LPG combustion were estimated using emission factors for natural gas combustion.  Luke AFB is not taking credit for any boilers installed with Low NOx burners and has based all emissions on standard AP-42 emission factors.
The make, model, and heat input rating for each of the external combustion units was obtained from the boiler plate or specification sheet of each unit.  Potential natural gas usage for each of the units was calculated using the maximum hours of operation per year (8,760 hr/yr).
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table C 1 is a Potential to Emit Summary of criteria pollutants from external combustion sources shown in full display in Appendix A of this TSD under the ECOM tab in the embedded icon cited above.
Table C 1

                                  Pollutants
                                   Emissions
                                      CO
                                      NOx
                                      SOx
                                     PM10
                                     PM2.5
                                      VOC
                                   tons/year
                                   lbs/year
                                     48.41
                                   96,818.16
                                     57.82
                                  115,647.19
                                     0.34
                                    688.17
                                     4.38
                                   8,761.86
                                     4.38
                                   8,761.86
                                     3.19
                                   6,387.73
Table C 2 is a Potential to Emit Summary of hazardous air pollutants (HAP) emissions from external combustion sources described above. The HAP emitted are speciated in the references cited above with only total HAP shown in this table.
Table C 2
                                     HAPs
                                   Emissions
                               Total (tons/year)
                                     0.086
                               Total (lbs/year)
                                    172.99

D.	FIRE FIGHTER TRAINING
Emissions Source Description: Luke AFB has a small scale fire fighter training facility used for periodic refresher training.  The training is performed in a live fire training pit including a mock-up aircraft structure.  The fire is simulated through the use of a controlled propane burner.  Emissions from fire fighter training occur as a result of the combustion of the fuel burned and include criteria pollutants and a variety of HAPs (both organic and inorganic).
MCAPCR Rule 314 §303 defines fire fighter training as a trivial source ["Fire fighter training, training areas and training structures are exempt from needing a permit if the sole source of flame is a burner fueled by either liquefied petroleum gas or natural gas, with a British Thermal Unit (BTU) input per hour rating of less than 2,000,000 BTUs."]  However, Luke AFB wishes to include these operations under Air Quality Operating Permit No. V97-017 so it will not be necessary to apply for separate open outdoor burning permits.
Emissions Calculations: Emissions from fire fighter training were estimated by multiplying the amount of fuel combusted by the appropriate emission factor, as shown in the equation below.

      EPOL = Q x EF
      Where,
      EPOL = Emissions of a particular pollutant (lb/yr);
      Q = Quantity of fuel consumed per year (10[3] gal/yr for propane); and
      EF = Emission factor (lb/10[3] gal for propane).
Calculations were completed using emission factors from Air Emissions Guide for Air Force Stationary Sources (AFCEC, October 2014).  Emissions from fire fighter training were determined by taking the average of the fuel consumed during 2012 to 2014 (used as the 3-year baseline average), and scaling this number up by 4.21.  The factor of 4.21 is the ratio of the maximum number of hours per year (8,760) to current average actual site operating hours of eight hours per day, five days per week, 52 weeks per year (2,080 hours per year), which conservatively assumes that fire fighter training at Luke AFB would increase proportionately to base operations.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table D 1 is a Potential to Emit Summary of criteria pollutants from fire fighter training sources shown in full display in Appendix A of this TSD under the FIRE tab in the embedded icon cited above.
Table D 1

                                  Pollutants
                                   Emissions
                                      CO
                                      NOx
                                      SO2
                                      VOC
                                     PM10
                                     PM2.5
                                   tons/year
                                   lbs/year
                                     0.25
                                    505.71
                                     0.91
                                    1829.08
                                    0.0033
                                     0.66
                                     0.39
                                    788.11
                                     0.16
                                    311.96
                                     0.16
                                    311.96
Table D 2 is a Potential to Emit Summary of hazardous air pollutants (HAP) from fire fighter training sources described above. Total HAP are shown in this table but the calculation sheet includes emissions for the HAP species formaldehyde as well.
Table D 2
                                     HAPs
                                   Emissions
                               Total (tons/year)
                                     0.011
                               Total (lbs/year)
                                     22.99

E.	FUEL CELL MAINTENANCE
Emissions Source Description: Luke AFB performs maintenance, repair, and routine inspection of the F-16 fuel cells, which are the fuel storage tanks on the aircraft.  Although fuel cell maintenance while the fuel cells remain on the aircraft is considered to be a mobile source of emissions by the Air Force, the F-16 has two external fuel cells which may be removed and maintained in a dedicated facility at Luke AFB.  For this reason, fuel cell maintenance is included in these calculations.
Fuel remaining in the fuel cell and fuel foam are removed prior to inspection and maintenance of the fuel cell.  Fuel cell maintenance is a source of VOC and HAP emissions from both the removal of fuel from the fuel cell into bowsers and from subsequently purging the fuel cell with clean air until the cell may be entered by maintenance personnel.  Emissions from the evaporation of fuel from any explosion suppression foam removed from the cell is assumed to be negligible due to the strict Air Force Technical Order requirements that all removed foam must be immediately sealed to prevent fuel vaporization. Fuel cell defueling emissions are the result of vapors displaced from the bowser tank by fuel from the fuel cell (and back again).  The emissions from the loading of fuel to and from the bowsers (during the defueling process) are addressed in Section G-Fuel Loading following.  Refueling of the fuel cell occurs on the flight line once the cells have been put back on the aircraft and is considered a mobile source.
Emissions Calculations: Calculations were completed in accordance with the methodology shown in Section 13 of the Air Emissions Guide for Air Force Stationary Sources (AFCEC, October 2014). Emissions from the purging and ventilation of the fuel cell is related to the vapor concentration of the fuel in the fuel cell and the amount of residual fuel clinging to the interior surfaces of the cell that remains after removing the fuel from the fuel cell.  However, these parameters can be difficult to determine, so emissions are conservatively estimated to be equal to the product of the saturation concentration of the vapor in the fuel cell and twice the fuel cell volume, as shown in the equation below.
      EVOC = CVOC x 0.13368 x 2 x ∑(V x N)
      Where,
      EVOC = Annual emissions of VOC (lb/yr);
      2 = Factor used for the conservative estimate of emissions representing twice the fuel cell volume;
      CVOC	= VOC concentration in the fuel cell (lb/ft[3]);
      0.13368 = Factor for converting cubic feet to gallons (ft[3]/gal);
      V = Fuel cell volume (gal/unit); and
      N = Number of fuel cells purged/ventilated in a year (units/yr).
The vapor saturation concentration (CVOC) was first estimated using the vapor molecular weight, vapor pressure and temperature of JET-A, as shown in the equation below.
      CVOC = (MV x PVA) / (R x TLA)
      Where,
      MV = Vapor molecular weight (lb/lb-mol);
      PVA = Vapor pressure at the daily average liquid surface temperature (psia);
      R = Ideal gas constant (10.732 psia::ft[3]/°R::lb-mol); and
      TLA = Daily average liquid surface temperature (°R).
The properties of JET-A were taken from Table 13-1 of the Air Emissions Guide for Air Force Stationary Sources (AFCEC, October 2014).
Speciated HAP emissions were calculated by multiplying the VOC emissions with the JET-A vapor-phase weight fraction of a particular HAP.
Maximum emissions from fuel cell maintenance were estimated using the maximum number of fuel cells purged in a year.  The maximum number of fuel cells purged in a year was determined by taking the number of fuel cells purged in 2007 (used as baseline year), and scaling this number up by 4.21.  The factor of 4.21 is the ratio of the maximum number of hours per year (8,760) to current average actual site operating hours of eight hours per day, five days per week, 52 weeks per year (2,080 hours per year), which conservatively assumes that fuel cell maintenance at Luke AFB would increase proportionately to base operations.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table E 1 is a Potential to Emit Summary of criteria pollutants from fuel cell maintenance sources shown in full display in Appendix A of this TSD under the CELL & DEFUEL tabs in the embedded icon cited above.
Table E 1

                                   Emissions
                                      VOC
                                   tons/year
                                   lbs/year
                                     0.955
                                    1910.45
Table E 2 is a Potential to Emit Summary of hazardous air pollutants from fuel cell maintenance sources described above. Only total HAP are shown in this table but they are speciated in Appendix A.
Table E 2
                                     HAPs
                                   Emissions
                               Total (tons/year)
                                     0.009
                               Total (lbs/year)
                                    18.053

F. 	FUEL DISPENSING-GASOLINE
Emissions Source Description: Luke AFB has one gasoline dispensing location used primarily to refuel government vehicles (Building 335).  Fuel dispensing is a source of VOC and HAP emissions.  Vehicle refueling emissions are the result of vapors displaced from the vehicle tank by dispensed fuel, from spillage of fuels from pre-fill and post-fill nozzle drip, and from "spit-back" and overflow from the fuel tank filler neck on the vehicle during filling.  Breathing and working emissions from the storage tanks are addressed with Fuel Storage.
At Luke AFB, gasoline dispensing currently involves the use of Stage II Vapor Recovery.  However, in accordance with EPA policy, Luke AFB plans to phase out Stage II systems pending instruction from Maricopa County.  For this reason, a control efficiency is not claimed for the use of Stage II Vapor Recovery in conjunction with emission calculations for gasoline dispensing.
At Building 335, gasoline is transferred into gasoline delivery vehicles for distribution to other gasoline storage tanks on base.  These gasoline delivery vehicles are tested annually by an off-base contractor to ensure the vessels are vapor tight and leak free, in accordance with the requirements of MCAPCR Rule 352.  Emissions from the transfer of fuel into these vessels are accounted for as a part of the fuel dispensing calculations; emissions from the transfer of fuel from these vessels to other storage tanks are considered a part of storage tank working losses.
Emissions Calculations: The VOC emission factors for gasoline are 11 lb/10[3] gal for uncontrolled displacement emissions per AP 42, Section 5.2, Table 5.2-7 (EPA, June 2008).  VOC emissions were calculated using the equation shown below.
      EVOC = Q x 1/1,000 x EF
      Where,
   EVOC = Emissions of VOC (lb/yr);
   Q = Annual quantity of fuel transferred (gal/yr);
   1/1,000 = Factor for converting gallons to 1,000-gallons (gal/10[3] gal); and
   EF = Emission factor (lb/10[3] gal).
Speciated HAP emissions were calculated by multiplying the VOC displacement emissions with the vapor-phase weight fraction of a particular HAP.
Maximum VOC and HAP emissions from fuel dispensing operations were estimated using fuel usage quantities previously submitted to the MCAQD during the last renewal. The calculated emissions are lower than the applicability threshold for the Subpart CCCCCC, of the National Emission Standards for Hazardous Air Pollutants for Source Categories: Gasoline Dispensing Stations", codified at 40 CFR §63.11110 through §63.11132.  Therefore, that federal regulation does not apply to the gasoline dispensing operations at Luke AFB.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table F 1 is a Potential to Emit Summary of criteria pollutants and HAP from fuel dispensing-gasoline sources shown in full display in Appendix A of this TSD under the FDSP-Gas tab in the embedded icon cited above.
Table F 1

                                   Emissions
                                      VOC
                                   tons/year
                                   lbs/year
                                      6.6
                                   13,199.87
Table F 2 is a Potential to Emit Summary of hazardous air pollutant emissions from fuel dispensing-gasoline sources described above. Only total HAP are shown in this table but they are speciated in Appendix A.
Table F 2
                                     HAPs
                                   Emissions
                               Total (tons/year)
                                     0.197
                               Total (lbs/year)
                                    394.68

G. 	FUEL LOADING-DIESEL & JET A
Emissions Source Description: Luke AFB has loading racks where diesel and JET-A are dispensed from large tanks into tank trucks (See the definition of delivery vessel in the regulations).  Fuel loading is a source of VOC and HAP emissions.  Loading losses are the result of vapors displaced from the fuel tank during loading of the fuel.
Fuel is transferred from Tanks 350 and 359 to five aboveground fuel loading racks through a pipeline within the base. Fuel can also be piped directly from Tanks 351 and 356 to the loading racks.    From the loading racks, the fuel is loaded into base tank trucks and distributed to aircraft on the flight line or to the smaller storage tanks located throughout the base for use in equipment and vehicles.  All loading is submerged, dedicated service.
Aircraft defueling (unloading of JET-A into a bowser) as a part of fuel cell maintenance activities (as described in Section E) is also included under fuel loading.  However, other aircraft defueling and refueling on the flight line is considered a mobile source and is not addressed in this renewal.  Refer to Section 7.0 for additional information on excluded sources.
Emissions Calculations: VOC emissions from fuel loading operations are calculated in accordance with the loading loss equation provided in AP-42, Section 5.2 (EPA, June 2008).  VOC emissions were calculated using the equation shown below.
      EVOC = Q x 1/1000 x 12.46 x S x P x M / T x [1-(CAPeff/100 x CONeff/100)]
      Where,
      EVOC = Annual emissions of VOCs (lb/yr);
      Q = Annual quantity of fuel transferred into the tanks (gal/yr);
      1/1000 = Factor for converting gallons to 1,000-gallons (gal/10[3] gal);
      12.46 = Equation constant (°R lb-mol/psia 10[3] gal);
      S = Saturation factor;
      P = True vapor pressure of fuel (psia);
      M = Vapor molecular weight of the fuel (lb/lb-mol);
      T = Temperature of bulk liquid loaded (°R);
      CAPeff = Capture efficiency of the loading terminal (%);
      CONeff = Efficiency of the control device (%); and
      100 = Factor for converting a percent to a fraction (%).
Speciated HAP emissions were calculated by multiplying the total VOC displacement emissions against the vapor phase weight fraction of each HAP in the fuel.  Capture and control efficiency were set at 0% to allow for a conservative estimate of emissions.
The maximum amount of fuel loaded in a year was determined by taking the usage in 2007 (used as baseline year), and scaling this number up by 4.21.  The factor of 4.21 is the ratio of the maximum number of hours per year (8,760) to current average actual site operating hours of eight hours per day, five days per week, 52 weeks per year (2,080 hours per year), which conservatively assumes that fuel loading at Luke AFB would increase proportionately to base operations.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table G 1 is a Potential to Emit Summary of criteria pollutants from fuel loading-diesel and Jet A sources shown in full display in Appendix A of this TSD under the FLD-DF2, JET A tab in the embedded icon cited above.
Table G 1

                                   Emissions
                                      VOC
                                   tons/year
                                   lbs/year
                                     28.54
                                   57,083.3
Table G 2 is a Potential to Emit Summary of hazardous air pollutant from fuel loading-diesel and Jet A sources described above. Only total HAP are shown in this table but they are speciated in Appendix A.
Table G 2
                                     HAPs
                                   Emissions
                               Total (tons/year)
                                     0.27
                               Total (lbs/year)
                                    540.34

H.	FUEL STORAGE
Emissions Source Description: Luke AFB stores fuel in multiple storage tanks.  All fuel tanks contain one of three fuel types:  jet fuel (JET-A), gasoline, or diesel/biodiesel.  Evaporative regulated air pollutants from fuel storage tanks include VOC and organic HAP which occur as a result of working losses when the tanks are filled and breathing losses while the tanks are storing fuel.
JET-A Storage Tanks: JET-A fuel is received through an interstate pipeline that transfers fuel to Tanks 351 and 356.  Tanks 351 and 356 are external floating roof tanks with capacities of 420,000 and 1,680,000 gallons, respectively.  Fuel is then transferred from Tanks 351 and 356 into Tanks 350 and 359.  Tanks 350 and 359 are fixed roof tanks, each with a capacity of 210,000 gallons.  Fuel is transferred from Tanks 350 and 359 to five aboveground fuel loading racks through an internal pipeline.  Loading rack operation is discussed in Section 6.4.
Tank 366 contains up to 25,000 gallons JET-A.  Tank 366 receives JET-A from aircraft de-fueling or excess fuel when cleaning tanker trucks.  Fuel from Tank 366 is then transferred into either Tank 351 or 356.
Gasoline and Diesel Storage Tanks: Tanks 367 and 368 contain up to 50,000 gallons diesel and 25,000 gallons gasoline, respectively.  Tanks 367 and 368 receive fuel from an outside contractor.
Building 2201 has a 1,000-gallon gasoline convault AST.  This tank receives gasoline from an outside contractor.
Building 335 is a service station, which provides gasoline and diesel fuel to military vehicles for base operations.  Fuel is delivered to the government service station by a contractor, and fuel delivery pumps are essentially identical to retail gas station units, meeting weights and measure standards.
Insignificant Tanks: Smaller diesel and gasoline fuel storage tanks at Luke AFB (e.g., built in generator fuel storage tanks) are considered an insignificant source in accordance with MCAPCR Appendix D ["Chemical or petroleum storage tanks or containers that hold 250 gallons or less and would have emissions of a regulated air pollutant."]. See also County Rule 100 §200.63 for the definitions of insignificant activities.
Luke AFB also has tanks storing liquids considered to have a low vapor pressure (virgin oil, flush oil, hydraulic oil, antifreeze, etc.).  These tanks are also considered an insignificant source in accordance with MCAPCR Appendix D ["Any emissions unit, operation, or activity that handles or stores no more than 12,000 gallons of a liquid with a vapor pressure less than 1.5 psia."]. See also County Rule 100 §200.63 for the definitions of insignificant activities.
Emissions Calculations: Maximum emissions from fuel storage tanks were estimated using previously permitted maximum fuel usage limits and individual tank characteristics (tank diameter, shell length/height, etc.).  VOC emissions from fuel storage tanks were estimated using methods outlined in Section 7.1.4 of AP-42.  Calculations were completed within the Air Program Information Management System (APIMS) by inputting the tank properties and fuel throughputs.  HAP emissions were calculated by multiplying total VOC emissions by the vapor weight fraction of each HAP in the fuel.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table H 1 is a Potential to Emit Summary of criteria pollutants from fuel storage sources shown in full display in Appendix A of this TSD under the STORAGE tab in the embedded icon cited above.
Table H 1

                                   Emissions
                                      VOC
                                   tons/year
                                   lbs/year
                                     8.77
                                   17,545.44
Table H 2 is a Potential to Emit Summary of hazardous air pollutants from fuel storage sources described above. Only total HAP are shown in this table but they are speciated in Appendix A.
Table H 2
                                     HAPs
                                   Emissions
                               Total (tons/year)
                                     0.246
                               Total (lbs/year)
                                    493.19

I.	JET ENGINE TEST CELLS
 Emissions Source Description: Two F-16 aircraft engines are tested at Luke AFB: F100-PW-220 and F100-PW-229.  This renewal addresses emissions from engines that have been removed from aircraft and are tested in dedicated test cells.  These cells are permanent fixtures with noise-reducing enclosures, sometimes referred to as hush houses.  Testing conducted on engines that are still attached to the aircraft are considered mobile and are not included in this application.  Testing usually involves combustion of JET-A fuel in various simulated aircraft operating scenarios (such as idle or approach modes).  Emissions from aircraft engine testing occur as a result of the combustion of the fuel burned and include criteria pollutants and a variety of HAPs (both organic and inorganic).
 Emissions Calculations: Emissions from jet engine testing were estimated by multiplying the number of tests per year per mode by the appropriate emission factor, as shown in the equation below.
      EPol = FFR x 1/1,000 x TTest x EFPol
      Where,
      EPol = Emissions (lb/yr);
      FFR = Fuel flow rate per mode (lb/hr);
      1/1,000 = Factor for converting gallons to 1,000-gallons (gal/10[3] gal);
      TTest = Total annual time engine testing occurred while operating at the applicable fuel flow rate (hr/yr); and
      EFPol = Emissions factor (lb/10[3] lb).
Maximum times in mode were taken from the test cell technical operating procedures.  The maximum number of tests in a year was determined by taking the usage in 2007 (used as baseline year), and scaling this number up by 4.21.  The factor of 4.21 is the ratio of the maximum number of hours per year (8,760) to current average actual site operating hours of eight hours per day, five days per week, 52 weeks per year (2,080 hours per year), which conservatively assumes that jet engine testing at Luke AFB would increase proportionately to base operations.
Fuel flow rates and emission factors for each mode were taken from Air Emissions Guide for Air Force Mobile Sources (AFCEC, October 2014).  Emission factors in units of lb/gal for sulfur dioxide (SO2) were derived by assuming all the sulfur in the fuel is converted to sulfur oxides (SOx) during combustion.  As described in the Air Emissions Guide for Air Force Stationary Sources (AFCEC, October 2014), the emission factor for SOx is obtained using the following equation: EFSOx = 20S; where S is the weight percent of sulfur in the fuel.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table I 1 is a Potential to Emit Summary of criteria pollutants from jet engine test cell sources shown in full display in Appendix A of this TSD under the JET tab in the embedded icon cited above.
Table I 1

                                  Pollutants
                                   Emissions
                                      CO
                                      NOx
                                      SO2
                                      VOC
                                     PM10
                                     PM2.5
                                   tons/year
                                   lbs/year
                                     13.17
                                   26,338.62
                                     31.52
                                   63,052.69
                                     0.90
                                   1,893.23
                                     4.25
                                   8,498.11
                                     2.25
                                   4,506.91
                                     2.25
                                   4,506.91

Table I 2 is a Potential to Emit Summary of hazardous air pollutants from jet engine test cell sources described above. Only total HAP are shown in this table but they are speciated in Appendix A.
Table I 2
                                     HAPs
                                   Emissions
                               Total (tons/year)
                                     0.41
                               Total (lbs/year)
                                    825.15
J.	MISCELLANEOUS CHEMICAL USE AND SURFACE COATING
 Emissions Source Description	 for Miscellaneous Chemical Use at Luke AFB includes cleaners, solvents, light lubricants, oils, adhesives, sealants and other materials.  These are chemicals which are used up in process and emissions are uncontrolled.  The primary regulated air pollutants associated with miscellaneous chemical usage are VOC and organic HAP.  Emissions of these pollutants are a result of product evaporation.  A majority of the chemicals used contain no inorganic HAP or solids, and spray application is minimal.  Therefore, PM emissions from general chemical use are considered to be negligible.
 Emissions Calculations for Miscellaneous Chemical Use are calculated based on a material balance.  The emissions of each pollutant are calculated by multiplying the volume of chemical product used by the density of the chemical product and then by the weight fraction (weight percent divided by 100) of the pollutant in the chemical product, as shown in the equation below.
      EPOL = QC x D x (WP/100)
      Where,
      EPOL = Emissions of a particular pollutant (lb/yr);
      QC = Quantity of chemical product used (gal/yr);
      D = Density of the chemical product (lb/gal);
      WP = Weight percent of the pollutant in the chemical product (%); and
      100 = Factor for converting weight percent to weight fraction.
Luke AFB uses the Environmental Management Information System (EMIS); a comprehensive database tracking system for all material authorization and issues.  When a material is authorized by base personnel, it is entered into the database, including health and safety information, physical and chemical properties and constituent breakdown from the material Safety Data Sheet (SDS).  Many National Stock Numbers (NSN) are repeated since facilities are authorized to purchase any one specific cage (manufacturer) listed.  Emissions are overstated by having duplicate NSN calculations, but each manufacturer usually has different constituents.  In order to accurately report what is used, all possible products are accounted for.
Emissions from miscellaneous chemical use were determined by taking the emissions from 2007 EMIS data (used as the baseline average for this source), and scaling this number up by 4.21.  The factor of 4.21 is the ratio of the maximum number of hours per year (8,760) to current average actual site operating hours of eight hours per day, five days per week, 52 weeks per year (2,080 hours per year), which conservatively assumes that miscellaneous chemical use at Luke AFB would increase proportionately to base operations.
Emissions Source Description	 for Surface Coating operations are performed by a variety of shops on an Air Force installation, including corrosion control shops, structural maintenance shops, munitions maintenance shops, vehicle maintenance shops, hobby shops, etc.  Surface coating operations involve the application of primers, paints (e.g., enamels, lacquers, polyurethanes, thinners, stains, varnishes, shellacs, glazes, etc., for decorative and protective purposes.  The types of regulated air pollutants from surface coating include VOCs, organic HAPs, PM, and inorganic HAPs.  The type and quantity of emissions are dependent on the composition of the surface coating material, the application technique, and whether or not a control device is used.
Surface coating operations at Luke AFB are categorized under Operating Permit
No. V97-017 as: "Aerospace Manufacturing and Rework", "Vehicle and Mobile Equipment Coating", "Spray Coating Operations", "Architectural Coatings", and "Surface Coating Operations", as determined by MCAPCR Rules 348, 345, 315, 335, and 336, respectively.  Aerospace coating operations at Luke AFB include coating of F-16 aircraft, aerospace ground equipment and rework at Buildings 922, 1018 and 1019.  Vehicle refinishing operations at Luke AFB include coating of government vehicles operated by the federal government at Building 291.  Spray Surface and spray coating operations at Luke AFB include coating of furniture, appliances, plastic products, and signs at Buildings 339 and 415.  In addition, the booth in Bldg. 339 is occasionally used for architectural coatings.
All surface coating operations at Luke AFB except for those performed at Building 247 are enclosed coating operations utilizing high-volume low-pressure (HVLP) spray equipment to apply the coatings.  Information on the types of controls used at each surface coating location is provided in Appendix A.
Manual (touch-up) and aerosol can application of coatings inside the spray booth at Building 247 is considered insignificant ["Any equipment or activity using no more than one gallon per day of surface coating or any combination of surface coating and solvent, which contains either VOC or hazardous air pollutants (HAPs) or both."]. Additional general exemptions are specified by MCAPCR Rules 348, 345, 315, 335, and 336, and are not listed in this application (e.g., MCAPCR Rule 348 §§308.4: Cotton-tipped swabs used for very small cleaning operations and aqueous cleaning solvents are exempt from the requirements of Section 307 of this rule.).
Emissions Calculations for Surface Coating are performed using Safety Data Sheet (SDS) information and a material balance.  VOC and organic HAP emissions from surface coating are estimated in the same manner as described above for Miscellaneous Chemical Use.  Particulate matter emissions from surface coating operations are also calculated based on a material balance, and take into account the transfer efficiency of the application method and control efficiency of the control device.  Emissions of particulate matter are calculated as shown in the equation below.
      EPOL = QC x D x (WP/100) x [1  -  (TE/100)] x [1  -  (CE/100)] x Cpol
      Where,
      EPOL = Emissions of a particular pollutant (lb/yr);
      QC = Quantity of chemical product used (gal/yr);
      D = Density of the chemical product (lb/gal);
      WP = Weight percent of the pollutant in the chemical product (%);
      TE = Transfer efficiency (%):
      CE = Control efficiency (%);
      CPol = Fractional percentage of PM10 or PM2.5 to total PM; and
      100 = Factor for converting weight percent to weight fraction.
Similar to miscellaneous chemical use, surface coating usage and SDS information is tracked using EMIS.  To allow for a conservative estimate, it was assumed that 100% of particulate sprayed would not be transferred and either emitted directly to the atmosphere or to a filter system if conducted within a booth.  Booth filter efficiency was conservatively set low at 95%.
Emissions from surface coating were determined by taking the emissions from 2007 (used as the baseline average for this source), and scaling this number up by 4.21.  The factor of 4.21 is the ratio of the maximum number of hours per year (8,760) to current average actual site operating hours of eight hours per day, five days per week, 52 weeks per year (2,080 hours per year), which conservatively assumes that surface coating at Luke AFB would increase proportionately to base operations.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table J 1 is a Potential to Emit Summary of criteria pollutants from miscellaneous chemical and surface coating sources shown in full display in Appendix A of this TSD under the MISCSURF tab in the embedded icon cited above.
Table J 1

                                  Pollutants
                                   Emissions
                                      CO
                                      NOx
                                      SO2
                                      VOC
                                     PM10
                                     PM2.5
                                   tons/year
                                   lbs/year
                                      NA
                                      NA
                                      NA
                                     53.27
                                  106,538.77
                                     0.86
                                   1,728.52
                                     0.86
                                   1,728.52
Table J 2 is a Potential to Emit Summary of hazardous air pollutants from miscellaneous chemical and surface coating sources described above. Only total HAP are shown in this table from Appendix A.
Table J 2
                                     HAPs
                                   Emissions
                               Total (tons/year)
                                      6.7
                               Total (lbs/year)
                                   13,412.16

K.	SOLVENT CLEANING (DEGREASING)
 Emissions Source Description	: Luke AFB operates multiple degreasing units which are commonly used by maintenance shops to clean (or degrease) parts associated with a variety of vehicles and equipment.
In maintenance cleaners, dirty parts cleaned in remote reservoir tanks are manually sprayed with solvent, possibly brushed, and allowed to dry before being removed from the cleaner.  The waste solvents are drained to a remote reservoir that captures drainage from the sink and acts as a pump sump for the spray.  The cover is closed whenever parts are not being processed or allowed to drip dry in the cleaner.
The regulated air pollutants from solvent cleaning machines include VOCs and HAPs from product evaporation; however, the solvents used at Luke AFB do not contain HAPs.  Therefore, only VOC emissions are being authorized from solvent cleaning units operated at Luke AFB.
Some facilities use aqueous parts washers where the detergent used does not contain VOC's.  These units are considered a trivial source in accordance with MCAPCR Appendix E ["Storage tanks, vessels, containers holding or storing liquid substances that will not emit any VOC or HAPs.  Exemptions for storage tanks containing petroleum liquids or other VOCs should be based on size limits and vapor pressure of liquids stored and are not appropriate for this list."].
Emissions Calculations: Maximum VOC emissions were calculated using the equation shown below.
      EVOC = Q x D x (1-R/100)
      Where,
      EVOC = Emissions of VOC (lb/yr);
      Q = Solvent Used (gal/yr);
      D = Solvent Density (lb/gal); and
      R = Percent Recovered (%).
The maximum amount of each type of solve used determined by taking the usage in 2007 (used as baseline year for this source), and scaling this number up by 4.21.  The factor of 4.21 is the ratio of the maximum number of hours per year (8,760) to current average actual site operating hours of eight hours per day, five days per week, 52 weeks per year (2,080 hours per year), which conservatively assumes that solvent cleaning at Luke AFB would increase proportionately to base operations.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table K 1 is a Potential to Emit Summary of criteria pollutants from solvent cleaning sources shown in full display in Appendix A of this TSD under the DEGR tab in the embedded icon cited above.
Table K 1

                                   Emissions
                                      VOC
                                   tons/year
                                   lbs/year
                                     3.46
                                   6,930.44
L.	INTERNAL COMBUSTION EMISSIONS:
Emissions Source Description: Luke AFB has two types of stationary internal combustion engines.  The majority of the engines are emergency generators which are used to provide emergency backup power to facilities/systems when the primary electrical power is not available; however, Luke AFB also has two general purpose generators (located in buildings 1034 and 1074)which are used to provide electricity for the base as required. While some of these older engines may otherwise be subject to 40 CFR 63, Subpart ZZZZ requirements, the facility has a National Security exemption from those requirements under 40 CFR 1068 C.
Emissions from internal combustion occur as a result of the combustion of the fuel burned and include criteria pollutants and a variety of HAPs.  The emissions from internal combustion units depend on a variety of factors including the size/type of the combustor, firing configuration, fuel type, control devices used, and operating capacity.
Smaller stationary internal combustion engines at Luke AFB with a maximum equipment rating of less than 50hp are considered an insignificant source in accordance with MCAPCR Appendix D ["Any piston-type IC engine with a manufacturer's maximum continuous rating of no more than 50 brake horsepower (bhp)."]. See also County Rule 100 §200.63 for the definitions of insignificant activities.
Emissions Calculations: Emissions from stationary internal combustion sources were calculated using the equation below:
      EPOL = OT x PO X LF/100 X EFPOL
      Where,
      EPOL = Emissions of a particular pollutant (lb/yr);
      OT = Operating time (hr/yr);
	PO = Rated power output of engine (hp);
	LF = Engine load factor (%); 74% per AEI Guide, Table 28-2; and
	EFPOL = Emissions factor (lb/hp-hr).
Power rating for each of the generators was obtained from base records and by visiting as many generators as possible to verify the information.  The maximum hours of operation for each of the engines was set based on the EPA memorandum "Calculating Potential to Emit (PTE) for Emergency Generators", which states that an engine cannot operate for more than 500 hours per year and be considered an emergency generator (EPA, September 1995).  Emissions factors were taken from Table 28-3 and 28-4 of the AEI Guide.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table L 1 is a Potential to Emit Summary of criteria pollutants from internal combustion sources shown in full display in Appendix A of this TSD under the ICOM tab in the embedded icon cited above.
Table L 1

                                  Pollutants
                                   Emissions
                                      CO
                                      NOx
                                      SO2
                                      VOC
                                     PM10
                                     PM2.5
                                   tons/year
                                   lbs/year
                                     16.35
                                   32,702.08
                                     72.8
                                   145,713.4
                                     3.92
                                   7,838.24
                                     5.02
                                   10,032.48
                                     4.59
                                   9,196.42
                                     4.59
                                   9,196.42
Table L 2 is a Potential to Emit Summary of hazardous air pollutant from internal combustion sources as described above. The hazardous air pollutants emitted from these sources are shown only in total in the table below but are also speciated in the referenced documents.
Table L 2
                                     HAPs
                                   Emissions
                               Total (tons/year)
                                     0.059
                               Total (lbs/year)
                                    117.88
M.	WOODWORKING
Emissions Source Description	: Most Air Force installations have a few organizations that operate woodworking equipment (e.g., saws, sanders, etc.).  The use of woodworking equipment generates airborne PM in the form of small wood waste particles (shavings, sander dust, sawdust, etc.).  In most cases, the airborne particulate is captured by a ventilation system and control device.  The control device used is either a cyclone, a baghouse (fabric filter), or both in series.  The sawdust captured by the control device is then collected in a bin or other container that is emptied when full.  All processes at Luke AFB are manually operated.
Luke AFB currently operates a baghouse to control air emissions at Building 247, two cyclones to control air emissions at Buildings 339 and 415, and a Roto Clone Hopper to control air emissions at Building 339.  For the purposes of emission estimations, the Roto Clone Hopper is treated as equivalent to a cyclone. All other woodworking activities utilize hand held or manually operated equipment that exhaust into the work space and are considered an insignificant source in accordance with MCAPCR Appendix D ["Hand-held or manually operated equipment used for buffing, polishing, carving, cutting, drilling, machining, routing, sanding, sawing, surface grinding, or turning of ceramic art work, precision parts, leather, metals, plastics, fiberboard, masonry, carbon, glass, or wood."]. See also County Rule 100 §200.63 for the definitions of insignificant activities.
Emissions Calculations: Emissions from woodworking were calculated by multiplying the amount of waste collected time the appropriate emissions factor per the equation below:
      EPOL = Q x EFPol x 1  -  (CAPeff/100 x CONeff/100)
      Where,
      EPOL = Emissions of a particular pollutant (lb/yr);
      Q = Annual quantity of wood waste hauled away (ton/yr);
      EFPol = Emissions factor (lb/ton wood waste hauled away);
      CAPeff = Capture efficiency (%);
      CONeff = Control efficiency (%); and
      100 = Factor for converting percent to fraction.
Emission factors for PM10 were taken from the Maricopa County Emissions Inventory Help Sheet for the Woodworking Industry (2014).  The capture and control efficiencies for the cyclones and baghouses were assumed to be 100% and 85%, respectively, in accordance with the Maricopa County Emissions Inventory Help Sheet for the Woodworking Industry (2014) for cyclones.
The maximum amount of sawdust collected at each location was determined by taking the usage in 2007 (used as baseline year for this source), and scaling this number up by 4.21.  The factor of 4.21 is the ratio of the maximum number of hours per year (8,760) to current average actual site operating hours of eight hours per day, five days per week, 52 weeks per year (2,080 hours per year) which it is conservatively assumes that woodworking operations at Luke AFB would increase proportionately to base operations.
Detailed emissions calculations and equipment information for all operations and equipment of the facility are shown in the embedded icons Appendix A Emissions Calculations and Equipment List above.
Table M 1 is a Potential to Emit Summary of criteria pollutants from woodworking sources shown in full display in Appendix A of this TSD under the WOOD tab in the embedded icon cited above.
Table M 1

                                   Emissions
                                  PM10/PM2.5
                                   tons/year
                                   lbs/year
                                     0.083
                                     165.3
N.	MISCELLANEOUS DISCUSSION ITEMS
Cooling Towers:
LAFB operates a central plant for heating and cooling that contains four cooling towers with a total maximum circulation rate of 3,900 gallons per minute. There are additional small cooling towers scattered throughout the facility but they are all of smaller capacity than the central plant towers. Appendix D of County Rules states that cooling towers with a circulation rate of less than 10, 000 gallons per minute are considered insignificant activities. Therefore, no permit conditions are being included in this permit for the operation of these cooling towers.
Waste Water Treatment Plant (WWTP):
The WWTP accepts municipal waste water discharges from facilities on the base. No industrial waste from Luke AFB is sent to the WWTP for treatment. The WWTP is designed to treat a maximum of 1.2 million gallons/day. The current throughput is approximately 425,000 gallons/day. A complete description of the WWTP was included in the application documents.
Fully treated effluent is sent to a storage pond where it is used as irrigation on the base. It can also be discharged to the Agua Fria River through an effluent metering flume to record the volume so discharged.
Emissions from the WWTP may include by-products of aerobic digestion such as carbon dioxide, methane, and trace amounts of hydrogen sulphide. No criteria or HAP emissions are expected from this process. These by-products may be odor producing and odor is regulated under this permit; however, there have been no odor complaints in the last five year permit period.
Open Outdoor Burning
LAFB occasionally conducts open outdoor burning and has applied for such burn permits as are required by County Rule 314 some of which have varying periods of expiration. It was decided to include open outdoor burning in this permit so that it will not be necessary to apply for separate open outdoor burning permits. Permission for burning must still be obtained for each burn conducted. Fire Fighter Training is conducted as part of the open outdoor burning operations
6.	INSIGNIFICANT AND TRIVIAL ACTIVITIES
Per MCAPCR Rule 100 §§200.58 and Appendix D, emissions do not need to be calculated for insignificant activities, however, the sources must be listed or generally grouped in the application.  The table below summarizes the sources at Luke AFB that meet the definition of insignificant.

                                  Source Type
                                      EPN
                                  Description
                              Exclusion Rationale
                               Boilers/Heaters/
                                 Water Heaters
                         Multiple  -  See Source List
                               Boilers/Heaters/
                                Water heaters
                              <300,000 Btu/hr
Appendix D: General Combustion Activities establishes a threshold for these sources as greater than 300,000 Btu/hr.

All natural gas and/or liquefied petroleum gas-fired pieces of equipment over 300,000 BTU per hour, only if the input capacities added together are less than 2,000,000 BTU per hour, the emissions come from fuel burning, and the equipment is used solely for heating buildings for personal comfort or for producing hot water for personal use.

It is implied that water heaters <300,000 Btu/hr are insignificant.
                                Cooling Towers
                         Multiple  -  See Source List
   Cooling Towers with circulation rate of 3,900 gallons per minute or less
Appendix D: Miscellaneous Activities.  Cooling towers: Any water cooling tower which: (1) has a circulation rate of less than 10,000 gallons per minute; and (2) is not used to cool process water, water from barometric jets, or water from barometric condensers.
                        Stationary Internal Combustion
                         Multiple  -  See Source List
                         Emergency generators <50hp
Appendix D: Internal Combustion (IC) Equipment.  Any piston-type IC engine with a manufacturer's maximum continuous rating of no more than 50 brake horsepower (bhp).
                                  Woodworking
                         Multiple  -  See Source List
   Hand held or manually operated equipment that exhaust into the work space
Appendix D: Miscellaneous Activities.  Hand-held or manually operated equipment used for buffing, polishing, carving, cutting, drilling, machining, routing, sanding, sawing, surface grinding, or turning of ceramic art work, precision parts, leather, metals, plastics, fiberboard, masonry, carbon, glass, or wood.
                               Abrasive Blasting
                         Multiple  -  See Source List
                            Small Glove Box Blaster

                                 Storage Tanks
                         Multiple  -  See Source List
           Gasoline, Diesel and JET-A Storage Tanks <250 gal cap.
Appendix D: Storage And Distribution.
Chemical or petroleum storage tanks or containers that hold 250 gallons or less and would have emissions of a regulated air pollutant.
Any emissions unit, operation, or activity that handles or stores no more than 12,000 gallons of a liquid with a vapor pressure less than 1.5 psia.

                         Multiple  -  See Source List
          Generator fuel storage tanks (Diesel) - various capacities

                         Multiple  -  See Source List
Tanks storing liquids considered to have a low vapor pressure (virgin oil, flush oil, hydraulic oil, antifreeze, etc.)

                                Surface Coating
                                   Multiple
Paint booth [in a designated (clean) shop area] in which manual application of materials is the sole method of application.
Appendix D: Surface Coating And Printing Equipment.
Any equipment or activity using no more than one gallon per day of surface coating or any combination of surface coating and solvent, which contains either VOC or hazardous air pollutants (HAPs) or both.

Per MCAPCR Rule 100 §§200.111 and Appendix E, "Trivial activities" means activities, process, or emissions units, such as the following, that may be omitted from a Title V permit application.  The table below summarizes the sources at Luke AFB that meet the definition of trivial.

                                  Description
                              Exclusion Rationale
                                    Welding
Appendix E: Repair And Maintenance.  Plant maintenance and upkeep activities (e.g., grounds keeping, general repairs, cleaning, painting, welding, plumbing, re-tarring roofs, installing insulation, and paving parking lots), provided these activities are not conducted as part of a manufacturing process, are not related to the source's primary business activity, and not otherwise triggering a permit modification.  Cleaning and painting activities qualify, if they are not subject to VOC or HAP control requirements.  Asphalt batch plant owners and/or operators must still get a permit, if otherwise required.
                         Miscellaneous Chemical Use[1]
Appendix E: Repair and Maintenance.  Plant maintenance and upkeep activities (e.g., grounds keeping, general repairs, cleaning, painting, welding, plumbing, re-tarring roofs, installing insulation, and paving parking lots), provided these activities are not conducted as part of a manufacturing process, are not related to the source's primary business activity, and not otherwise triggering a permit modification.  Cleaning and painting activities qualify, if they are not subject to VOC or HAP control requirements.  Asphalt batch plant owners and/or operators must still get a permit, if otherwise required.
And
Repair or maintenance shop activities not related to the source's primary business activity (excluding emissions from surface coating or degreasing (solvent metal cleaning) activities) and not otherwise triggering a permit modification.
             Solvent Cleaning (Degreasing) Using Aqueous Solvents
Appendix E: Storage And Distribution.  Storage tanks, vessels, containers holding or storing liquid substances that will not emit any VOC or HAPs.  Exemptions for storage tanks containing petroleum liquids or other VOCs should be based on size limits and vapor pressure of liquids stored and are not appropriate for this list.
                    Fire Suppression Systems
(e.g., AFFF)
Appendix E: Emergency Equipment.  Fire suppression systems.
[1]Miscellaneous chemical emissions estimates may include emissions from activities that would be considered insignificant to allow for a conservative estimate.

Additionally, the table below summarizes sources that are not defined insignificant or trivial per MCAPCR, but can be justifiably excluded from permitting.

                                  Description
                              Exclusion Rationale
                              Aircraft Defueling
Both pieces of equipment are mobile; not a stationary source.
                     Jet Engine Spray Ring Matter Burn Off
Jet engine spray rings are pre-cleaned prior to placement in burn off ovens.  Any debris remaining is invisible to the naked eye.  The burn-off ovens are exempted from the requirements of MCAPCR Rule 313 per email "RE: Rule 313" from Patty Nelson  -  ENVX<EMAIL_ADDRESS>to Newell Yvonne I Civilian 56 CES/CEVC, Thursday May 06, 2004 1:55 PM.
                             Oil water separators
Generally used only for JET-A, oils, and other heavy materials mixed with water.  Units are constant level, underground units (i.e., no working or breathing losses) and assumed to have no evaporative emissions.
                        Portable Jet Engine Test Stand
Considered a mobile source.
                          Portable Fuel Storage Tanks
Not a stationary source.
                             Outdoor Firing Range
Shooters are mobile; not a stationary source.

APPENDIX A

APPENDIX A

APPENDIX A EXTERNAL COMBUSTION

APPENDIX A

APPENDIX A

APPENDIX A

APPENDIX A FUEL LOADING-DIESEL & JET A

APPENDIX A

APPENDIX A FUEL STORAGE

APPENDIX A FUEL STORAGE EMISSIONS

APPENDIX A

APPENDIX A JET ENGINE TESTING

APPENDIX A JET ENGINE TESTING

APPENDIX A JET ENGINE TESTING

APPENDIX A JET ENGINE TESTING

APPENDIX A MISCELLANEOUS CHEMICAL USE AND SURFACE COATING

APPENDIX A

APPENDIX A

APPENDIX A INTERNAL COMBUSTION

APPENDIX A