Understanding the EPA guidance on major source determinations for military installations
- Dept. of the Navy, Washington, DC (United States)
In August 1996, the Environmental Protection Agency (EPA) issued the first ever Clean Air Act (CAA) guidance directed specifically at military facilities. The Guidance, titled Major Source Determinations for Military Installations under the Air Toxics, New Source Review and Title V Operating Permit Programs of the Clean Air Act, was negotiated by an EPA/DoD workgroup that included field and headquarters EPA and DoD representatives, and was led by the Navy. This paper describes the development and contents of the guidance and the significant legal and policy issues raised. By statute and rule, all sources under common control on contiguous or adjacent property and belonging to the same two digit Standard Industrial Classification (SIC) Code must be aggregated when determining if the source is a major source. DoD requested that EPA develop the guidance because of a move by EPA to impose a fenceline-to-fenceline interpretation of what constitutes a major source for purposes of the three programs identified above. Such an interpretation could and did result in more stringent regulation of industrial sources on military installations than of similar industrial plants. The guidance establishes EPA`s allowable interpretation of two of the three key elements of the major source definition. First, the guidance specifies that common control occurs at the military service level; therefore, sources belonging to the Army, Navy, Marine Corps, Air Force, the National Guard or a Defense Agency that are located on the same installation could each be treated separately. Second, the guidance allows the military to assign SIC codes to functional industrial groupings in a manner similar to the private sector. Past practice grouped all national defense activities under the same SIC code.
- OSTI ID:
- 353524
- Report Number(s):
- CONF-970677-; TRN: IM9929%%70
- 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.
- Country of Publication:
- United States
- Language:
- English
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