Original Date: 02/23/1998
Revision Date: 01/18/2007

Northrop Grumman’s Environmental Resources Department implemented a very proactive process to minimize the negative effects of Title V regulations. The company incorporated an internal, user-friendly network that generates reports necessary for Title V compliance. Northrop Grumman’s effort, along with careful, long term permit projections, will enable the company to operate in full compliance within the stringent California regulations.

Northrop Grumman’s Environmental Resources Department implemented a very proactive process to minimize the negative effects of Title V regulations. The company incorporated an internal, user-friendly network that generates reports necessary for Title V compliance. Northrop Grumman’s effort, along with careful, long term permit projections, will enable the company to operate in full compliance within the stringent California regulations.

The Title V amendment of the Clean Air Act is a federally-operated permitting program administered by EPA- approved state programs. The increased monitoring, record keeping, and reporting elements contained in this program make it one of the most intensive air regulations to date. The program also requires mandatory self- reporting of non-compliance, and is enforceable by the EPA and citizens’ suits. A key aspect of Title V is that it consolidates all air quality requirements to a single, five-year plan for a contiguous facility. Therefore, planning and projection are critical to having a comprehensive permit submission because the lengthy revision process can take up to two years to work its way through the system. Public notification and approval by local agencies as well as the EPA are also requirements of the revision process. The forecasting of these delays and the effective planning for future production requirements are excellent models for other aerospace companies.

Northrop Grumman’s previous system did not have environmental provisions for new projects, and relied on the design review approval process to identify equipment which needed permits. This often led to delays in projects and put schedules at risk. In addition, the equipment permits and related data were maintained in manual files. The company’s new system provides source-by-source linkage with existing emission and equipment data; standardizes reports which are expandable to new requirements; and provides real-time data of hazardous waste usage and emission streams. The system also integrates an Annual Operating Plan (AOP) and quarterly surveys to obtain early warnings of potential environmental impacts. The AOP centralizes plans and potential projects from Northrop Grumman’s operating elements, and has become the mechanism for communicating environmental requirements to program planners and engineers throughout the company. An effective tool developed to gather this information was the Environmental Planning Checklist which identifies such areas as equipment using hazardous materials or generating fumes; alteration of exhaust ventilation systems or sewer connections; anticipated changes in production rates; and closure of an existing facility.

Already planning for the difficult process of obtaining amendments to the Title V permit, the Environmental Organization has secured flexible permits which will meet production requirements into the foreseeable future. Early comprehensive permitting for the new F/A-18 E/F Painting Technology Facility allows construction of seven paint booths and associated boilers. This permitting will allow a variety of processes to be utilized in the aerospace industry while maintaining compliance to volatile organic compound (VOC) emissions within the existing cap. Other particulars include allowing for phased construction as needed; providing for production expansion and business diversification; and using existing emission allowances.

To process and organize data required to complete reports necessary for Title V permitting, Northrop Grumman utilizes its Chemical Tracking System (CTS). This system incorporates a chemical review process of hazardous chemicals, provides procurement controls, inspection programs, chemical tracking, and remote metering of critical hazardous equipment. The CTS has been an instrumental tool in achieving pollution prevention objectives. In addition, the system also maintains regulatory compliance records, prevents unauthorized use of chemicals, and provides data for reporting taxes and fees.

The costs of early permitting are very minimal compared to those associated with schedule delays. Northrop Grumman’s proactive permitting process, along with the visions and preparations put forth by the Environmental Organization, have positioned the company as a leader in environmental compliance for the aerospace industry.

For more information see the Point of Contact for this survey.