Permitting of Federal Facilities by SIC Major GroupDavis-Monthan AFB Case Study

摘要

Air Force facilities have historically been encouraged by their Command Headquarters tornconsider minor source or synthetic minor source status under CAAA regulations. Basesrnwith minor source operating permits can avoid Title V and NESHAP Major Sourcernregulatory status.rnIn 1998, Davis-Monthan AFB accepted voluntary permit limits in order to achievernsynthetic minor source status for hazardous air pollutants (HAPs). This permit allowedrnthe Base to operate in a manner that is protective of the environment and public healthrnwhile avoiding the extensive operational constraints, recordkeeping, and reportingrnrequirements that would have been triggered by the Aerospace NESHAP if the Base hadrnbeen designated a Major Source for HAPs.rnWhen the Base's Title V Permit application was due to be updated in 1999, BasernEnvironmental Staff determined that the Base could, with minimal additional permitrnrequirements, achieve synthetic minor source status for criteria pollutants. This was donernby organizing basewide operations according to standard industrial classification (SIC)rnMajor Groups. This paper will describe the strategy used in the developmentrnof the Base's seven synthetic minor permits. The key objectives of this strategy were:rn? Designing permit conditions that are enforceable as a practical matter;rn? Minimizing the time required for recordkeeping and compliance demonstration;rn? Minimizing the number of steps (potential failure points) in data collection andrnrecordkeeping;rn? Minimizing the number of people involved in routine data collection andrnrecordkeeping;rn? Maximizing operating flexibility within the permit limits; andrn? Defining concise standards for compliance demonstration.rnThe achievement of these objectives required cooperation and creative contributions fromrnshop Environmental Coordinators, Base Environmental Staff, Base Command Staff, andrnlocal regulators. This paper will present specific examples of permit conditions alongrnwith explanations of how and why these permit conditions were developed.