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Title: Major sources to waivers - lessons learned and $ saved at two U.S. Navy facilities

Naval Surface Warfare Center Carderock Division (NSWCCD) manages 17 US Navy research and development (R and D) facilities across the country. These include two facilities in Maryland -- one in Annapolis and the other in West Bethesda which is better known as Carderock. NO{sub x} is the only air emission which exceeds a threshold limit at both properties. The potential to emit NO{sub x} is 72 tpy for Annapolis and 51 tpy for Carderock. The facilities are in different counties but each county has a trigger limit for NO{sub x} of 25 tpy making both facilities major sources. In preparation for the Title V permit applications to the state of Maryland, Carderock budgeted $150,000 in fiscal year 1996 to have a contractor conduct air emission inventories and prepare the Title V permits for both Carderock and Annapolis. However, the Carderock Air Program Manager did not pursue a contractor to perform the work but personally conducted the air emission inventory for both Annapolis and Carderock. Noticing a large difference between the potential-to-emit and the actual emissions of NO{sub x}, the Air Program Manager began negotiations with the Maryland Department of the Environment (MDE) to waive the requirement for the Title Vmore » permit application. MDE responded in December 1996 that if the facility`s actual emissions would not exceed 50% of any of the threshold limits during any 12 month period, then a letter of understanding stating such should be submitted to MDE. This letter of understanding would be recognized by the US EPA and MDE and would act as a waiver to the Title V permit applicability up to July 31, 1998. Carderock and Annapolis meet this requirement and letters of understanding were drafted and sent to MDE in January 1997.« less
Authors:
 [1]
  1. Naval Surface Warfare Center, West Bethesda, MD (United States). Carderock Div.
Publication Date:
OSTI Identifier:
353522
Report Number(s):
CONF-970677--
TRN: IM9929%%68
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; MILITARY FACILITIES; AIR POLLUTION ABATEMENT; NITROGEN OXIDES; MARYLAND; EMISSION; CLEAN AIR ACTS; LICENSES; AIR POLLUTION MONITORING; COMPLIANCE