Waynesboro: Comments on Northrop Grumman permit request raise issues to DEQ

We’ve had two local residents share with us the comments they sent to the Virginia DEQ regarding the request from Northrop Grumman for a state operating permit that would allow for the release of 24.9 tons of hazardous air pollutants at a planned advanced electronics assembly and testing facility.

There’s still time to weigh in – either at the public hearing that will be held at Waynesboro High School on Thursday, with a scheduled start time of 6:30 p.m., or by email or snail mail to the Valley Regional Office of the DEQ – get the email in by the end of the business day on Thursday, and if you’re going the snail-mail route, I’d recommend a July 23 postmark.

Contact for public comments, document requests and additional information:
Debbie Medlin, Valley Regional Office
4411 Early Road, Rockingham, VA 22801
Phone: 540-217-7071
E-mail: [email protected]

Comment: Janet Melton, Augusta County

---

I am writing to have this email included in the public record noting my opposition to the current NG draft air state operating permit (SOP). This email is going to be somewhat lengthy as I have researched and have specifics to include.

1. Environmental legal case against Northrop Grumman: Bethpage, N.Y., April 12, 2022 E.D.N.Y. Docket No. 22-CV-2101 Northrop Grumman sued because of infractions of the federal Comprehensive Environmental Response, Compensation and Liability Act (CERCLA).
2. Extremely worrisome that the current administration continues to relax previously established federal standards of the Environmental Protection Agency. We, as citizens of Augusta County and Virginia, need to maintain our vigilance and fight against the possibility of local environmental disasters and contaminations.
3. DuPont’s environmental contamination in Waynesboro and other parts of the U.S. Hundreds of miles of local waterways impacted at the time. Current “do not eat” advisory remains (stocked trout exception) for 24 miles of local waterway. Pay attention and learn from the past. We cannot and should not let this happen again because of poor oversight and planning or money or the promise of jobs. Shortsighted decisions and lapses in sound judgement have long-term consequences.
4. Waynesboro and its surrounding areas are considered environmental justice communities. There are laws which protect citizens from environmental harms.  Be proactive not reactive. Too much is at stake. The buck will eventually stop.

Seven key musts to demand of NG in their SOP:

1. Must have enforceable limits as described in the engineering analysis.
2. Must release complete draft mNSR permit. Make it public knowledge and available.
3. Must include enforceable limits for equipment and materials.
4. DEQ must provide full facility-wide potential-to-emit (PTE) calculations including boilers and emergency generators.
5. Must include emergency generator requirements and compliance standards.
6. DEQ must include records and restrictions for target metal Hazardous Air Pollutants (HAPs). Coatings cannot be introduced without prior DEQ review and permission.
7. NG must utilize Best Available Control Technology (BACT). Odor and polysulfide controls must have enforceable limits by means of air modeling and third party testing which must include documents and reports.

Our citizenry may not fully understand the science and technicalities involved in the operation of the NG facility, but we will be the ones to suffer if specific controls aren’t implemented now.

Our beautiful, surrounding mountains are blue because of the natural phenomenon of isoprene emissions. Let’s keep our mountains blue and our populations of people, animals, and plants protected and healthy.

Comment: D. Cabell Vest, Waynesboro

---

I submit these comments during the public comment period (June 18 – July 23, 2026) on the above-referenced draft State Operating Permit. I am a resident of Waynesboro and the owner of Rose Cliff, a circa-1850 Greek Revival residence listed on the Virginia Landmarks Register (DHR File Number 136-5051).

I write not as a technical expert but as a longtime member of this community who cares deeply about the air, water, and quality of life that define life in Waynesboro — and who believes that this application raises serious questions that DEQ must carefully weigh before issuing a permit.

I. Waynesboro has already borne more than its share of industrial pollution.

Any fair assessment of this permit application must begin with history. For generations, Waynesboro served as the host community for major industrial operations — including DuPont and General Electric — whose legacy of pollution endures to this day. The South River remains contaminated with mercury from GE’s decades of operations, a remediation challenge so vast and long-running that it has become part of the permanent landscape of life here. The damage from that era was not merely environmental; it was a breach of the basic trust that communities place in industry and in the regulators charged with protecting them.

I raise this history not to relitigate the past but because it is directly relevant to the present application. A community’s cumulative pollution burden — what regulators sometimes call environmental justice — is a legitimate consideration in permitting decisions. Waynesboro has already paid a price that many communities never have. The question before DEQ is not simply whether Northrop Grumman’s proposed emissions fall within 1 the statutory definition of a minor source. The question is whether this permit is appropriate for this community, at this location, given what has already been borne here.

II. Waynesboro is an open-windows community — and that matters.

There is a reason the community adjacent to Waynesboro is called Stuarts Draft. The Shenandoah Valley is a place defined by its air — by the movement of wind through mountain gaps and down river corridors, by the seasons marked as much by what you can smell as by what you can see. Waynesboro residents live with their windows open. We know when farmers are fertilizing their fields miles away. We know when the wind shifts. We are not an industrial airshed community, and we have not consented to become one.

III. The location of this facility warrants heightened scrutiny.

The facility at 1001 Shenandoah Village Drive sits at the confluence of multiple sensitive receptors. Within a quarter mile: dense residential development and planned senior housing. Within half a mile: Coyner Springs, the municipal water intake, and the South River. Within four miles: three schools and a hospital. And beyond the city limits, the airshed extends into the Shenandoah Valley at large — a nationally significant landscape that encompasses the Blue Ridge Parkway and Shenandoah National Park. DEQ’s own permit summary acknowledges this reach. A facility whose emissions are controlled by nothing more than usage limits, sited at this location, demands far more rigorous analysis than a minor-source designation would typically require.

IV. The draft permit appears to contain technical deficiencies.

I am not a technical expert, and I do not submit this comment as one. However, I am aware, through media coverage of this proceeding, that at least one registered environmental manager has identified specific technical deficiencies in the draft permit. Those concerns include, among others: the absence of enforceable limits described in the engineering analysis (including MIBK hourly emission limits, polysulfide throughput limits, and odor-control requirements); the non-availability to the public of the referenced minor NSR permit, without which the draft SOP cannot be meaningfully evaluated; equipment specifications listed as informational rather than enforceable; gaps in the facility-wide potential-to-emit calculations; missing federal compliance requirements for emergency generators under 40 CFR Part 60 Subpart IIII; and the unenforceability of NESHAP non-applicability determinations regarding toxic metal coatings.

Without adopting or vouching for the technical accuracy of those observations, I respectfully request that DEQ examine whether those concerns have merit and give them full consideration in its final permit decision. If they are well-founded, the permit should not be issued as currently drafted.

V. The original public notice process was inadequate.

I also wish to note my concern about the process by which this permit came before the public. The initial draft permit notice was published in a single local newspaper with a print circulation of approximately 692, publishing only three days per week — a publication that, by any reasonable measure, no longer serves as the primary news source for the residents most affected by this facility. The result was that 250 community members submitted comments during the initial period despite — not because of — the notice process, and the volume of those comments is what triggered the public hearing now before us. DEQ should examine whether its notice requirements are adequate for siting decisions of this significance, and should consider whether more robust community engagement is warranted before any permit is issued.

VI. Requests

For the foregoing reasons, I respectfully request that DEQ:

1. Deny the permit as currently drafted, or at minimum require installation of active emissions control equipment — not merely use restrictions — before any permit is issued;
2. Conduct a meaningful environmental justice analysis that accounts for Waynesboro’s historical cumulative pollution burden, the proximity of sensitive receptors, and the community’s reasonable expectation of clean air;
3. Examine and address the technical deficiencies in the draft permit identified through public media coverage of this proceeding, and make the complete permit package — including the referenced minor NSR permit — available for public review;
4. Require independent, third-party air quality monitoring during facility operations as a condition of any permit issued; and
5. Reform the public notice process for future permit actions of this nature to ensure that affected residents receive meaningful advance notice through channels they actually use.

Waynesboro is not opposed to economic development. Situated at the gateway to Shenandoah National Park and Skyline Drive, flanked by the George Washington and Jefferson National Forests and the Blue Ridge Parkway, and graced by the South River and a network of city trails, ours is a community of extraordinary natural distinction — a destination of choice for those who live here and those who visit, and home to a planned campus of the Virginia Museum of Natural History that speaks to how Waynesboro sees its own future. We welcome good jobs and responsible industry that honor that setting rather than diminish it. But we have learned — at great cost — that not all development is compatible with community health, and that the consequences of permitting decisions can last for generations. DEQ has an opportunity here to apply the lessons of this region’s history rather than repeat them. I urge the Department to do so.

Comment: Enviromental manager

---

I also got this from a registered environmental manager who laid out a case for the Virginia DEQ to, if not outright deny the permit request, at the least put severe restrictions on what Northrop Grumman would be able to do at its Waynesboro location.

I’m presenting his comments without attribution.

1. The draft SOP does not include key enforceable limits described in the engineering analysis.
   The engineering analysis states that state-only enforceable limits are necessary for MIBK hourly emissions, polysulfide odor control, and daily polysulfide throughput. However, the draft SOP contains only facility-wide HAP limits of 9.9 tons/year for any individual HAP and 24.9 tons/year combined HAPs. It does not include the MIBK hourly limit, the one-pound-per-day polysulfide limit, or the charcoal/HEPA odor-control requirement described in the analysis. DEQ should revise the permit to include these requirements or identify the separate draft mNSR permit where they are enforceable.
2. The public should be given the complete permit package. The engineering analysis repeatedly refers to minor NSR permit conditions for spray booths, solvent recovery, cooling towers, woodworking, MIBK, odor, and BACT. The attached draft SOP does not include those conditions. DEQ should make the draft mNSR permit available for review during the comment period, because the SOP cannot be meaningfully evaluated without it.
3. The permit should include enforceable operating limits for equipment and materials. The SOP equipment list states that equipment specifications are “informational only” and not enforceable. That weakens the permit because the engineering analysis relies on assumptions such as spray booth capacity, solvent recovery capacity, cooling tower drift, and generator use. DEQ should convert necessary assumptions into enforceable permit terms.
4. DEQ should add full facility-wide potential-to-emit calculations. The engineering analysis excludes the boilers and emergency generators from the minor NSR PTE table because they are treated as Article 6 exempt units. Even if that is appropriate for minor NSR applicability, DEQ should provide a full facility-wide PTE table for Title V and synthetic minor review, including boilers and emergency generators.
5. Emergency generator requirements should be included. The engines are subject to federal emergency engine requirements under 40 CFR Part 60 Subpart IIII. The permit should include non-resettable hour meter, fuel sulfur, emergency-use, maintenance/testing, and recordkeeping requirements to preserve the claimed exemption and ensure compliance.
6. NESHAP non-applicability should be made enforceable. The analysis states that 40 CFR Part 63 Subpart HHHHHH is not applicable because no coatings containing chromium, lead, manganese, nickel, or cadmium will be used. The permit should require records or restrictions sufficient to ensure that target metal HAP coatings are not introduced without prior DEQ review.
7. Odor and polysulfide controls need enforceable terms. The engineering analysis relies on localized odor control and low polysulfide usage to avoid odor BACT. The final permit should include the promised controls, throughput limits, inspection/maintenance requirements, and complaint-response procedures.

Conclusion from the environmental manager: “for these reasons, DEQ should not issue the permit as drafted unless the missing minor NSR conditions are made available and the final permits include enforceable limits matching the assumptions used in the engineering analysis.”

ICYMI: Northrop Grumman permit request

---

• Waynesboro: No help coming from environmentalists on Northrop Grumman permit
• Game plan coming together on how to fight Northrop Grumman pollution permit
• 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
• How Waynesboro residents can challenge the Northrop Grumman pollution permit