We still haven’t been able to generate any interest from the various environmental advocacy organizations in Virginia to help Waynesboro fight back against the request for a state permit that would allow Northrop Grumman to release tons of hazardous air pollutants into our local environment.
Gotta admit here: makes me want to report less on their do-gooder efforts elsewhere going forward.
There must not be any money in helping little ol’ Waynesboro fight to keep its air and water clean.
And that’s what makes the world go ‘round – not doing the right thing to protect the environment, but rather, money.
I did get some valuable assistance 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.
First, some 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.
Objections
Our new environmental manager friend laid out seven specific objections to the permit request as submitted by Northrop Grumman:
- 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. - 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. - 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. - 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. - 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. - 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. - 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.”
Do note
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.
The public comment period on the request runs 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:
ICYMI: Northrop Grumman permit request
- 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
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Chris Graham
