I noted in a June 26 AFP column that I was going to reach out to folks at the Southern Environmental Law Center, the Sierra Club, the League of Conservation Voters and Appalachian Voters – to see if they can help locals in Waynesboro get prepared for the July 23 Virginia DEQ public hearing on the request of Northrop Grumman for a permit that would allow the release of tons of hazardous air pollutants into our local environment.
The thinking: this kind of thing is what these people do for a living, as opposed to me, whose experience with the environment is limited to keeping the lawn mowed and filling up the bird feeders.
Bad news: 10 days have passed, and no response.
Not even crickets.
Nothing.
This is not good, because the advice I got from an environmental lawyer with respect to this public hearing is: it’s not going to be enough for several hundred folks to show up at the public hearing to say “pollution: bad.”
People are going to need to be specific with objections, or, and this isn’t from me, but from our guy in the know: DEQ, which has a staff report on file from its Valley Regional Office recommending approval of the permit request, is going to lean in the direction of approving the request.
The experts at DEQ are telling us that this proposed limit of 24.9 tons of hazardous stuff going into environment is somehow acceptable; I’m betting most of us laypeople think the limit should be at or near zero.
It would be nice to get some help from someone in the know.
AI to the rescue!
In absence of help from living, knowledgeable environmental types, I’m having to settle for curated help from (shudder!) AI – the curation coming from the environmental lawyer who has been in contact with me about the permit application matter.
AI’s advice:
- Challenge the “synthetic minor” loophole: The analysis assumes Northrop Grumman will naturally stay under 24.9 tons. It can be argued that the permit lacks adequate continuous monitoring, record-keeping, or reporting requirements to actually prove they are staying below that cap. If they cannot prove compliance daily, the restriction is legally deficient.
- Attack the omission of modeling: Because it is a minor permit, DEQ did not do air dispersion modeling. Public commenters can submit evidence (or pull data from local weather stations) showing that Waynesboro’s unique geography — being in a valley — creates temperature inversions that trap airborne toxins (like methyl isobutyl ketone, toluene, and xylene) close to the ground, requiring localized air modeling regardless of the minor status.
- Target the odor mitigation plan: The analysis notes a charcoal filtration system will handle the highly odorous polysulfides. You can challenge the engineering specifications of this system. Is charcoal sufficient for the volume being used? How often must the filters be replaced?
- The toxins on the permit request can reasonably be captured or filtered: Highly advanced, commercially standard prophylactic technologies exist that can capture or destroy 95 percent to over 99 percent of these exact pollutants. The issue here: Northrop Grumman almost certainly does not want to have to spend the money on that, which is why they are desperate to keep their engineering analysis below 25 tons. If the permit is approved, there will not be any requirement for capture or filtration, and it will merely be honor system for them to keep it below 25 tons.
Details: How to be heard
The public hearing on the Northrop Grumman permit request will be held at Waynesboro High School on Thursday, July 23, with a scheduled start time of 6:30 p.m.
DEQ also announced the opening of another public comment period, running through the public hearing date on July 23.
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]
The public may review the draft permit and application at the DEQ office named above or may request copies of the documents from the contact person listed above.
The draft permit and draft engineering analysis can be viewed by clicking the document links below:
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Chris Graham
