Our crowdsourced effort to make sure the Virginia DEQ doesn’t screw us over with its handling of a request for permit that would allow Northrop Grumman to release tons of hazardous air pollutants into our local environment is gaining traction.
Though not, unfortunately, from the environmental advocacy groups with the staff and resources to really fight back.
Not yet, anyway.
I’m holding out hope.
But in the meantime, two environmental experts reached out to me after our report published on Monday on the topic of “How Waynesboro residents can challenge the Northrop Grumman pollution permit.”
ICYMI: Northrop Grumman
- 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
I’m not going to name names so as not to get any stink on them and make it harder for them to do what they do for a living, but just to be clear here – I can’t take credit for the work on this, because I’m not anywhere near this smart, at least with respect to environmental issues.
I’m your go-to guy on stick-and-ball sports; I wouldn’t take my word on environmental engineering.
It’s been explained well enough for me to be able to make some sense of things, which says a lot for the abilities of our experts, that they can break things down for a guy whose level of knowledge on the general topic flows out from the fact that he took Environmental Science 101 at UVA 35 years ago.
Note: the course was listed in the catalogue with an “N” to denote that it was “Not for Science Majors.”
Those of us in the College of Arts and Sciences who weren’t science majors figured that the “N” also stood for “Not That Difficult.”
And I still got a B.
First, the background
Northrop Grumman has filed a request 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.
The potential emissions, per the permit request, include volatile organic compounds and particulate matter.
VOCs, from our research, can lead to breathing issues and lung disease, and PMs are linked to cardiovascular issues, lung disease, stroke and cancers.
The location of the Northrop Grumman plant, near Coyner Springs, is a particular concern – the springs are where the city water treatment plant is located, and a creek that runs through the park leads to the South River, which means communities downriver could also be impacted.
A staff report on the request from DEQ notes that “within ¼ mile of the plant are 352 planned senior apartments, a heavy concentration of shopping, dining, and neighborhoods.”
“Within four miles there are three schools and a hospital. Coyner Springs, a municipal water supply and associated 145-acre recreational area with trails and a dog park, are less than ½ mile from the plant and the South River ½ mile further. The plant location puts all of these at risk of the highest toxic pollutant concentrations from the plant.”
That was from Trevor Wallace, the air permit manager in the Valley Regional Office of the DEQ, in a memo on the request dated May 21, in which he also noted that “the proposed emissions will affect the entire Shenandoah Valley, the Blue Ridge Parkway, and the Shenandoah National Park.”
In the face of these concerns, the Valley DEQ office is still recommending that the state agency approve the permit request.
The deck is obviously stacked against us.
Confirmation: Yep, the deck is stacked against us
One of the experts who reached out to me yesterday opined that it’s clear to him that “DEQ seems predisposed to grant this permit.”
“I do not know if ‘the fix is in’ on this, and the various environmental advocacy groups who should give a sh-t are so aware and feel the juice isn’t worth the squeeze,” was the message.
The recommendation from the expert: concerned citizens can file a statement with DEQ citing detailed and specific issues/flaws/defects with Northrop Grumman’s application and with DEQ’s treatment thereof.
“Those objections would then become the basis for any legal action subsequent to DEQ’s approval of the permit. Which, reading the tea leaves, seems likely,” I was told here.
The second expert laid into DEQ for the lack of transparency in the staff report – which does not appear to include the complete permit package, and skims over enforceable limits described in its engineering analysis.
“The biggest flaw is that the engineering analysis relies heavily on a separate minor NSR permit, but the attached draft permit appears to be only a 6-page State Operating Permit for synthetic minor HAP limits. If this is the only draft permit package, it is missing many of the conditions the engineering analysis says are essential,” the second expert related to me.
Another flaw: the lack of enforceable limits.
“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.”
What may need to happen here
I’m with the first expert on the point that, DEQ is ultimately going to approve the permit request, but that doesn’t have to be the end of this.
Get the objections on the record, and then we can see if somebody from the environmental advocacy community can bring their resources to bear on our behalf.
“The most fertile grounds for challenging the permit are going to involve scientific and engineering analyses that will be beyond nearly all lay citizens both in terms of expertise and expense, and the expenses and challenges of litigation should be obvious. Having an experienced and well-funded patron/advocate addresses both of those issues,” I was told.
Emphasis there on “well-funded.”
This isn’t something that even the most well-meaning of us is going to be able to do using spit and tape, and AI.
One other option:
“Perhaps if enough folks petition their local representatives to get at least one or two on ‘our’ side, some progress could be made. Of course, that obviously risks turning this political,’ and I very much fear the only hope for a satisfactory outcome is if there is a unified effort by the community.”
The game plan is starting to come together.
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Chris Graham
