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Title: Air permitting at military installations: Applying the EPA guidance for CAA major source determinations at DOD facilities

On August 2, 1996, the Environmental Protection Agency issued guidance to its regional offices concerning Clean Air Act major source determinations for military installations. Congress traditionally targeted permitting efforts at major sources of air pollution to focus controls on the larger emitters. Many regulations depend on whether a source is major or not. The Title I New Source Review (NSR) program, the Title III Air Toxics program, and the Title V Operating Permits program all use major source as a differentiating point for regulations. The Prevention of Significant Deterioration rules (1980) are the basis of the definition used by NSR, Title V, and Air Toxics. The rules define major source as an emissions source or sources under common control, grouped by Standard Industrial Classification (SIC) code, and located on continuous or adjacent property. In addition, support facilities are grouped with another facility if >50% of the output of the support facility directly supplies the source. EPA Region III made a major source determination for Virginia at Fort Belvoir, grouping all pollutant emitting activities within the fenceline together. Prior to this determination, permit authorities had the discretion to determine the grouping of functions within the fenceline. Military Installations contain a diversemore » group of activities such as industrial operations, training ranges, dry cleaners, housing areas, and food establishments. The responsibility and control are also diverse and can be controlled by military, contractor, and leased services. This paper will provide methods which facilities and their contractors can use when negotiating permits with their permitting authority. The principal methods are to use separate control to separate Military Services or leased activities, and to use functionally distinct groupings other than SIC 97 (National Security) to classify activities at military installations.« less
Authors:
 [1]
  1. Office of the Chief of Naval Operations, Arlington, VA (United States). Environment, Safety, and Occupational Health Div.
Publication Date:
OSTI Identifier:
351725
Report Number(s):
CONF-970677--
TRN: IM9927%%250
Resource Type:
Conference
Resource Relation:
Conference: 90. annual meeting and exhibition of the Air and Waste Management Association, Toronto (Canada), 8-13 Jun 1997; Other Information: PBD: 1997; Related Information: Is Part Of 1997 proceedings of the Air and Waste Management Association`s 90. annual meeting and exhibition; PB: [7000] p.
Publisher:
Air and Waste Management Association, Pittsburgh, PA (United States)
Country of Publication:
United States
Language:
English
Subject:
54 ENVIRONMENTAL SCIENCES; 29 ENERGY PLANNING AND POLICY; MILITARY FACILITIES; AIR POLLUTION; LICENSES; POLLUTION SOURCES; CLEAN AIR ACTS; COMPLIANCE; AIR POLLUTION ABATEMENT; TOXIC MATERIALS; LEGAL ASPECTS