Challenges in Maintaining Title Ⅴ Compliance at a Large Federal Facility (Tinker Air Force Base)

摘要

Tinker AFB is a major (Part 70) source for air emissions subject to a single Title Ⅴ permit covering activities of its major organization and a number of tenant organizations. While the regulated activities of these organizations share similarities, each organization is functionally distinct and separate. This presents a challenge in compliance with relevant air regulations, as each organization views its own activities and non-compliance incidents as its own, and tends not to learn from the mis-steps of the other organizations. It is hoped that this brief discussion of some incidents at Tinker AFB, and the role that fragmented management structures have played in these incidents, may be of benefit in prompting critical review of the interactions of various sub-organizations in relation to compliance with environmental regulations.