I just read through the 15-page “Summary of Public Comments and Responses: Northrop Grumman Systems Corporation” put out by the Virginia DEQ last week, in regard to the Northrop Grumman request for a state permit that would allow them to dump 24.9 tons of hazardous pollutants into the air each year over Waynesboro and surrounding areas.
Summing up the response from DEQ: sorry, our hands are tied, as it turns out, by us, ourselves.
I wish I was making this up.
I’ll note here: nobody signed their name to the report.
Can’t say that I blame whoever wrote it for not wanting to be held responsible.
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Off the top, the summary notes that DEQ received multiple requests to lower or zero out the emission limits – which the author tells us isn’t due to limitations in the current state regulatory structure, which “restricts the authority DEQ can exercise” in reviewing a request for a state operating permit.
Specifically, per the summary, when “a facility requests synthetic minor status, DEQ must process that application for that purpose; therefore, comments that do not pertain to the draft permit regarding the synthetic minor status of Northrop Grumman with respect to HAP major source thresholds are out of the scope of this action.”
So, what is this synthetic minor status thing that they’re talking about here?
Per the Virginia Regulatory Town Hall website, synthetic minor status is just a classification for “a facility that limits its potential air pollution emissions through enforceable permit conditions to stay below major source thresholds.”
Huh?
If this sounds like circular reasoning to you – synthetic minor status is a status defined by a permitting process, and because of how we define the permitting process, we can’t do anything about somebody requesting synthetic minor status – you’re where I am on this.
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The other big item in the DEQ summary involves requests from locals to have the state require “independent testing and monitoring (fenceline plus strategically nearby), with real-time publicly available emissions data and an alert system,” that “DEQ conduct air dispersion modeling,” and that the permit holds Northrop Grumman to “mandatory installation and operation of pollution control equipment.”
The response from DEQ here: sorry, no.
Here’s what the report spells out:
This SOP is to ensure synthetic minor status for HAP, which is an annual (12-month period) threshold. All portions of the draft permit serve that purpose. Compliance with annual emission limits must be demonstrated monthly via a 12‐month rolling total. This method is an established regulatory approach used statewide and nationally for the practical enforceability of annual limits. Each month, the facility must calculate emissions for the most recent 12‐month period and maintain records demonstrating that the rolling total remains below the applicable permit limits. These records are enforceable and must be made available to DEQ during inspections or upon request.
If you’re with me here, you see the flaw.
Northrop Grumman is the one keeping the records.
So, we just take their word for it, that they’re in compliance?
DEQ understands that some commenters view self‐reported data as insufficient. The monitoring, recordkeeping, and reporting requirements included in the draft permit meet the regulatory standards necessary to ensure compliance and provide DEQ with the information needed to evaluate the facility’s performance.
Unfathomable.
Take their word for it, basically.
Question: why are we even engaging in this stupid song and dance over a permit, if it comes down to the check and balance being records that the polluter is keeping on itself?
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Reinforcing that point, I’m highlighting one other matter from the DEQ summary, in which the author provides cover for Northrop Grumman from observations by locals to the effect that the permit request “appears intentionally structured to keep the facility classified as a synthetic minor source,’ allowing the company to stay just below HAP major source regulatory thresholds and thereby avoid more rigorous oversight, monitoring, and pollution control requirements.”
If you think that, you’re just, you know, wrong, man.
“Northrop Grumman requesting and voluntarily accepting HAP emission limits that are less than major source thresholds is not regulatory circumvention,” the report tells us. “Facilities accepting legally enforceable permit limits to ensure they remain below major source thresholds, for both HAP and criteria pollutants, is envisioned within DEQ’s air permitting programs and is a mechanism that has provided additional emissions reductions across DEQ’s air permitting programs.”
Tsk, tsk, for just assuming that this whole permitting process was paid for by the polluters so that they can keep on doing whatever the hell they want to do, however the hell they want to do it.
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Last thought on this today: has anybody noticed that nobody from among the state, regional and national environmental advocacy groups has pitched in to help us here in Waynesboro on this issue?
And I tried.
I reached out personally to all of the groups that have us on their email lists for news releases about all of the great things they’re doing to preserve environmental justice and whatever other BS they say they’re up to.
Not even a “no, we can’t help” in response.
Just, crickets.
If they can’t bother to even tell us to bugger off, I’m not giving them clicks anymore.
These groups are obviously just taking money from their donors to write reports that nobody will read and file frivolous lawsuits that make them seem like they’re up to something.
I’m not going to help them do that going forward.
ICYMI: Northrop Grumman in Waynesboro
- Northrop Grumman announces plans for $200M manufacturing facility in Waynesboro
- Waynesboro: DEQ needs to grant extension on Northrup Grumman SOP
- Waynesboro: DEQ to set public hearing on Northrup Grumman permit request
- Waynesboro: DEQ sets public hearing on Northrop Grumman permit request
- Locals gave Virginia DEQ an earful on Northrop Grumman permit request
- Waynesboro: DEQ says it’s OK for Northrop Grumman to pollute our environment
- Waynesboro leaders sold our clean air, water, for 300 low-tech jobs
- Waynesboro: DEQ sets second public hearing on Northrop Grumman pollution request
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Chris Graham
