AQ_F_0400052_20210726_CMPL_CompRpt

v/5
rankli Fn
Franklin Engineers&Consultants,LLC.
2734 Sunrise Blvd,Suite 308
Pearland,TX 77584
Engineers&Consultants,LLC. Phone: [phone]
July 23, 2021
Division of Air Quality
North Carolina Department of Environmental Quality RECEIVED
Fayetteville Regional Office
225 Green Street, Suite 714
Fayetteville,North Carolina 28301 JUL .2 2�21
RE: 1 st Half 2021 Title V Semi-Annual Report
pEp.FgyETEVILLE RENAL OFFICE
Anson County Landfill,Polkton,North Carolina
Facility Title V Permit No. 09835T04
To Whom It May Concern:
This letter and the attached documentation represent the Title V Semi-Annual Report for the
Anson County Landfill (ACL) located in Polkton,NC. This report has been prepared to satisfy
the requirements of Condition 2.1-A.Lg of Permit No. 09835T04.
If you have any questions concerning this information,please feel free to call Lana Brown at
[phone] or me at [phone].
Sincerely,
Franklin Engineers & Consultants, LLC.
Juene Franklin
President
Enclosure: ACL 1st Half 2021 Title V Semi-Annual Report
cc: w/attachment
Matt Crockett—WCN Eastern Region Engineering Manager(Electronic)
Lana Brown—WCN Eastern Region Environmental Compliance Specialist (Electronic)
Tyler Fitzgerald—WCN District Manager

ANSON COUNTY LANDFILL
POLKTON, NORTH CAROLINA
(AIR QUALITY PERMIT #: 9835T04)
(FACILITY ID # 0400052)
TITLE V SEMI-ANNUAL REPORT
REPORTING PERIOD January 1,2021 —JUNE 30,2021
WAs-m UJNNEC11ONS INC.
ray:nnu r wsx1t r w f-u-try°}
Prepared for
Anson County Landfill
Jul-21
Prepared by
Franklin Engineers & Consultants, LLC.
2734 Sunrise Boulevard, Suite 308
Pearland, TX 77584
[phone]
Project Number: 21-028

TABLE OF CONTENTS
1 INTRODUCTION............................................................................................................................ 1-1
1.1 PURPOSE........................................................................................................................................ 1-1
1.2 APPLICABILITY.............................................................................................................................. 1-1
1.3 PERMITTED EMISSION SOURCES AND POLLUTION CONTROL DEVICES........................................... 1-1
1.4 STATEMENT OF CERTIFICATION BY RESPONSIBLE OFFICIAL.......................................................... 1-1
2 SPECIFIC LIMITATIONS AND CONDITIONS........................................................................2-1
2.1 EMISSIONS SOURCES AND CONTROL DEVICES...............................................................................2-1
2.1.1 Emission Source Limits and Standards...............................................................................2-1
2.1.2 Notifications, Test Methods, and Procedures......................................................................2-1
2.1.3 Standards for Air Emissions from MSW Landfills'..............................................................2-1
2.1.4 Monitoring and Record-Keeping Requirements..................................................................2-2
2.1.5 Reporting.............................................................................................................................2-2
2.2 CONTROL OF VISIBLE EMISSIONS...................................................................................................2-2
2.3 TOXIC AIR POLLUTANT EMISSION LIMITATION AND REPORTING REQUIREMENT(FLARE).............2-3
2.4 TOXIC AIR POLLUTANT EMISSION LIMITATION REQUIREMENT(FACILITY-WIDE).........................2-3
3 GENERAL CONDITIONS.............................................................................................................3-1
3.1 GENERAL PROVISIONS,PERMIT AVAILABILITY,AND SEVERABIL.TTY.............................................3-1
3.2 SUBMISSIONS,DUTY TO COMPLY,CIRCUMVENTION,AND PERMIT MODIFICATIONS/CHANGES.....3-1
3.3 REPORTING REQUIREMENTS FOR EXCESS EMISSIONS AND PERMIT DEVIATIONS...........................3-2
3.4 EMERGENCY PROVISIONS AND PERMIT RENEWALS.......................................................................3-2
3.5 NEED TO HALT OR REDUCE ACTIVITY...........................................................................................3-2
3.6 DUTY TO PROVIDE AND INFORMATION AND SUPPLEMENT............................................................3-2
3.7 RECORDS RETENTION,COMPLIANCE CERTIFICATION,AND RO CERTIFICATION............................3-2
3.8 PERMIT SHIELDS,TERMINATION,MODIFICATION,AND REVOCATION...........................................3-3
3.9 INSIGNIFICANT ACTIVITIES............................................................................................................3-3
3.10 PROPERTY RIGHTS,INSPECTION AND ENTRY............................................................................3-4
3.11 ANNUAL FEE PAYMENT AND EMISSIONS INVENTORY REQUIREMENTS.....................................3-4
3.12 CONFIDENTIAL INFORMATION,CONSTRUCTION PERMITS,AND OPERATING PERMITS...............3-4
3.13 STANDARD APPLICATION FORM AND REQUIRED INFORMATION...............................................3-5
3.14 FINANCIAL RESPONSIBILITY AND COMPLIANCE HISTORY.........................................................3-5
3.15 REFRIGERANT REQUIREMENTS(STRATOSPHERIC OZONE AND CLIMATE PROTECTION)............3-5
3.16 PREVENTION OF ACCIDENTAL RELEASES(SECTION 112R)........................................................3-5
3.17 TITLE IV ALLOWANCES............................................................................................................3-6
3.18 AIR POLLUTION EMERGENCY EPISODE.....................................................................................3-6
3.19 REGISTRATION OF POLLUTION SOURCES...................................................................................3-6
3.20 AMBIENT AIR QUALITY STANDARDS........................................................................................3-6
3.21 GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS.............................................3-6
3.22 REOPENING FOR CAUSE............................................................................................................3-6
3.23 REPORTING REQUIREMENTS FOR NON-OPERATING EQUIPMENT...............................................3-7
3.24 FUGITIVE DUST CONTROL REQUIREMENTS...............................................................................3-7
3.25 SPECIFIC PERMIT MODIFICATIONS............................................................................................3-7
3.26 THIRD-PARTY PARTICIPATION AND EPA REVIEW.....................................................................3-7
11

I INTRODUCTION
1.1 Purpose
This document serves as the I'Half 2021 Title V Semi-Annual Report(SAR)prepared for the
Anson County Landfill(ACL). This report has been prepared to satisfy the requirements of the
existing Title V Operating Permit(Air Quality Permit No.9835T04).
1.2 Applicability
This facility has not yet exceeded the 34 Mg/yr threshold; therefore, neither the GCCS nor the
candlestick flare is required for installation at this facility. ACL currently satisfies the requirements
of 40 CFR 60, Subpart XXX and via Tier 2 Testing. At this time, the facility is not required to
comply with the requirements of 40 CFR 63, Subpart AAAA(Landfill MACT).
1.3 Permitted Emission Sources and Pollution Control Devices
The primary emission source for this facility is municipal solid waste landfill (MSWLF). The
primary control devices for this facility are the Landfill Gas Collection and Control System(GCCS)
and the 2,500 scfm candle-stick flare skid. Though neither the GCCS nor the candlestick flare are
required to be installed at this time,these control devices are voluntarily operated.
1.4 Statement of Certification by Responsible Official
In accordance with the requirements of Title V Permit Condition 3.Q, we have included a
certification by the Responsible Official.
I, the undersigned, certify that, based on information and belief formed after reasonable inquiry,
the statements and information in the document are true,accurate,and complete.
Responsible Official
Signature
Responsible Official Tyler Fitzgerald
Print
Responsible Official Title c.-� ft�A1166/1,
Date -?-�a a od l
1-1

2 SPECIFIC LIMITATIONS AND CONDITIONS
2.1 Emissions Sources and Control Devices
The following information details the specific conditions associated with the emission source
[MS WLF(ES-1] and associated air pollution control devices [GCCS (GCCS-1)and Candlestick
Flare(CD-1)].
2.1.1 Emission Source Limits and Standards
In accordance with the requirements of Section 2.1-A.1 of the existing Title V Permit,no
sulfur dioxide emissions have been recorded that exceed the 2.3 lb/MMBTU limit.
Additionally,no visible emissions in excess of 20%opacity as specified in 15A NCAC
2D.0521 have been recorded at ACL during this reporting period. The most recent Tier 2 Test
Report submitted on 3/29/21 for compliance with NSPS XXX,the NMOC emission rate is
greater than 34 Mg/yr(35.52 Mg/yr).
i
I�
2.1.2 Notifications, Test Methods,and Procedures
I
Test notifications,methods,and procedures indicated in Section 2.1-A.3.a and Section 2.1-
A.3.b of the existing Title V Permit,have been addressed for this reporting period. Any
future Tier 2 testing and notifications required,will be performed on or before December 27,
2023 in accordance with 40 CFR 60.764 as specified in Section 2.1-A.3.i of the existing Title
V Permit.
I I
2.1.3 Standards for Air Emissions from MSW Landfills
Since the NMOC emission rate for ACL exceeds the 34 Mg/yr threshold,GCCSDP must be
submitted to the NCDEQ no later than March 29,2022. The GCCSDP will be prepared by a
professional engineer who is registered in the state of North Carolina. The GCCSDP will be
prepared to comply with the requirements of Section 2.1-A.3.b of the existing Title V Permit.
Moreover,the GCCS will need to be expanded to comply with the requirements of Section
P PY q
2.1 —A.3.b.ii on or before September 29,2023.
I
2-1

2.1.4 Monitoring and Record-Keeping Requirements
For this reporting period,as specified in Section 2.1-A.3.q,ACL,the following up-to-date,
readily accessible,records(electronic or hard-copy)are either maintained onsite or as off-site
records that are retrievable within 4 hours:
• The Design Capacity Report which triggered§60.762(b);
• The current amount of solid waste in place;
• Year-by-year waste acceptance
jThe foregoing documents will be maintained onsite for at least five(5)years.
2.1.5 Reporting l
� I
At this time,the facility is only required to submit the typical six-month summary reports
required by Section 2.1-A.3.ee of the existing Title V Permit.
2.2 Control of Visible Emissions
Section 2 of the existing Title V Permit addresses visible emissions from the existing candlestick
flare(ES-1). Based on observations by site personnel,the candlestick flare(ES-1)has not
displayed an opacity greater than 20%when averaged over a six-minute period during this
reporting period. The existing candlestick flare(ES-1)operates on Landfill gas(LFG);therefore,
no monitoring,record-keeping,or reporting is required for visible emissions.
2-2

2.3 Toxic Air Pollutant Emission Limitation and Reporting Requirement(Flare)
Section 5.a of the existing Title V Permit stipulate that the following emission limits cannot be
exceeded:
DESCRIPTION TOXIC AIR POLLUTANT EMISSIONS LIMIT
Landfill ES-1 Fugitive Benzene 108.62lb
( ) Fu g /Yr
Emissions Hydrogen Chloride
-------------------
j Hydrogen Sulfide 3.16 Ib/day
Vinyl Chloride 96.56 Ib/yr
Candlestick Flare (CD-1) Benzene 5.26 Ib/yr
Hydrogen Chloride 0.59 Ib/hr
Hydrogen Sulfide 0.15 Ibs/day
Vinyl Chloride 4.66 Ib/yr
Based on the LFG generation rate of the landfill and the average LFG extraction rate of the flare,
the foregoing emission limitations have not been exceeded.
2.4 Toxic Air Pollutant Emission Limitation Requirement(Facility-Wide)
Section 6 of the existing Title V Permit stipulate that the facility-wide actual emissions, including
fugitives,do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC 2Q.0711.
Based on the LFG generation rate of the landfill and the average LFG extraction rate of the flare,
the TPERS have not been exceeded.
2-3

3 GENERAL CONDITIONS
This section of the report describes the terms and conditions that are applicable to ACL.
3.1 General Provisions,Permit Availability,and Severability
ACL personnel understand that the facility must be operated in accordance with Section 3-A of
the existing Title V Operating permit.
As indicated in Section 3-13 of the existing Title V Operating Permit,ACL will retain the
following documents onsite for the full duration of the permit term:
• One(1)copy of the Title V Operating Permit
• One(1)complete copy of Title V Permit Application and any supporting information
These documents can be made available to an authorized representative of the NCDEQ upon
request.
As specified in Section 3-C of the existing Title V Operating Permit,ACL understands that, in the
event of an administrative challenge to a final binding permit in which a condition is held to be
invalid,the provisions in the permit are severable so that all requirements contained in the permit,
except those held to be invalid,shall remain valid and must be complied with.
3.2 Submissions,Duty to Comply,Circumvention,and Permit Modifications/Changes
Though no reports were required during this monitoring period,ACL personnel will make certain
that two(2)copies of all future reports submitted to the appropriate Regional Office(Fayetteville
Regional Office)in compliance with Section 3-13 include the Facility Name and Facility ID
Number.
As stated in Section 3-E,ACL personnel understand that the facility must comply with all terms,
conditions,requirements,limitations,and restrictions set forth in this permit. ACL further
understands that any Noncompliance with any permit condition,except conditions identified as
state-only requirements,constitutes a violation of the Federal Clean Air Act and is grounds for
enforcement action,permit termination,revocation and reissuance,modification,or denial of a
permit renewal application.
In accordance with Section 3-F,ACL personnel have properly operated and maintained the
facility in a manner that effected an overall reduction in air pollution. Though a GCCS and flare
system are currently in place and operational at ACL,these control devices are not required for
compliance at this time. However,ACL has operated the GCCS and flare system on a voluntary
basis to effect an overall reduction in air pollution.
No changes to the Title V were prepared during this reporting period. Any changes that do or do
not require a permit modification will be prepared and submitted in accordance with the
requirements of Section 3-G and/or Section 3-H of the existing Title V Operating Permit.
3-1

3.3 Reporting Requirements for Excess Emissions and Permit Deviations
i
No excess emissions or permit deviations occurred during this reporting period.ACL personnel
will address Excess Emissions events or Permit Deviations in accordance with the requirements
of Section 3-I of the existing Title V Operating Permit.
3.4 Emergency Provisions and Permit Renewals
No emergencies occurred during this reporting period. Should any emergencies occur in the
future,they will be addressed in compliance with Section 3-J of the existing Title V Operating
Permit.
Also,note that no permit renewal was required for submittal during this reporting period. If a
permit renewal is required in the future it will be submitted in compliance with Section 3-K of the
existing Title V permit. Section 3-K indicates that the permit renewal application must be
submitted at least six(6)months before the date of permit expiration. The existing Title V Permit
will expire on January 31,2024;therefore,in compliance with Section 3-K,ACL personnel will
submit a renewal application no later than July 31,2023.
3.5 Need to Halt or Reduce Activity
As indicated in Section 3-L of the existing Title V Operating Permit,ACL personnel understand
that it shall not be a defense in an enforcement action that it would have been necessary to halt or
reduce a permitted activity in order to maintain compliance with the conditions of this permit.
3.6 Duty To Provide and Information and Supplement
As specified in Section 3-M of the existing Title V Operating Permit,ACL personnel will,upon
request by DAQ personnel,provide,in a timely manner,any reasonable information that the
Director may request in writing to determine whether cause exists for modify,revoking and
reissuing,or terminating the permit or to determine compliance. Moreover,when requested,
ACL personnel will provide any DAQ copies of records required to be kept by the permit.
Finally,upon request,ACL will submit records claimed to be confidential directly to the EPA
along with the claim of confidentiality. Please note that no DAQ document requests have been
made during this reporting period.
In the event that ACL personnel become aware that any relevant facts were omitted or incorrect
information was submitted in the permit application,they will,as indicated in Section 3-N of the
existing Title V Operating Permit,provide additional information as necessary to address any
requirement that becomes applicable to the facility after the date a complete permit application
was submitted prior to the release of the draft permit. Please note that no permit applications
were submitted during this reporting period.
3.7 Records Retention,Compliance Certification,and RO Certification
As specified in Section 3-0 of the existing Title V Operating Permit,ACL personnel have
retained records of all required monitoring data and supporting information for a period of at least
five(5)years from the date of the monitoring sample,measurement,report,or application. All
3-2

records are maintained in a form suitable for review and readily available for expeditious
inspection and review. Additionally,these records are kept onsite or can be retrieved from an off-
site location within four(4)hours and made available to DAQ personnel for inspection upon
request.
As specified in Section 3-P of the existing Title V Operating Permit,ACL personnel must submit
the Annual Compliance Certification(ACC)signed by a Responsible Official(RO)on or before
March 1,2021. The ACC must include all federally-enforceable terms and conditions in the
permit. The RY2020 ACC was submitted to the DAQ on January 28,2021;therefore,ACL has
satisfied this permit condition.
As specified in Section 3-Q of the existing Title V Operating Permit,a RO will certify the truth,
accuracy,and completeness of any application form,report,or compliance certification required
by the Title V Permit. All certifications shall state that based on information and belief formed
after reasonable inquiry,the statements and information in the document are true,accurate,and
complete.
3.8 Permit Shields Termination,Modification,and Revocation
As specified in Section 3-R of the existing Title V Operating Permit,ACL understands that a
permit shield does not apply to any change made at a facility that does not require a permit or
permit revision made under 15A NCAC 2Q.0523 or minor permit modifications made under 15A
NCAC 2Q.0515. ACL also understands that a permit shield shall not alter or affect any of the
following items:
• The power of the Commission, Secretary of the Department,or Governor under NCGS
143-215.3(a)(12),or EPA under Section 303 of the Federal Clean Air Act;
• The liability of an owner or operator of a facility for any violation of applicable
requirements prior to the effective date of the permit or at the time of permit issuance;
• The applicable requirements of Title IV; or
• The ability of the Director or the EPA under Section 114 of the Federal Clean Air Act to
obtain information to determine compliance of the facility with its permit
As indicated in Section 3-S of the existing Title V Operating Permit,ACL also understands that
the Director may terminate,modify,or revoke and reissue this permit if:
• The information contained in the application or presented in support thereof is
determined to be incorrect;
• The conditions under which the permit or permit renewal was granted have changed;
• Violations of conditions contained in the permit have occurred;
• The EPA requests that the permit be revoked under 40 CFR 70.7(g)or 70.8(d);
• The Director finds that termination,modification,or revocation and reissuance of the
permit is necessary to carry out the purpose of NCGS Chapter 143,Article 21B.
3.9 Insignificant Activities
In accordance with Section 3-T of the existing Title V Operating Permit,ACL will have available
onsite at all times and made available to an authorized representative upon request,
3-3

documentation, including calculations, if necessary,to demonstrate that an emission source or
activity is insignificant.
3.10 Property Rights,Inspection and Entry
As specified in Section 3-U of the existing Title V Operating Permit,ACL understands that the
permit does not convey any property rights in either real or personal property or any exclusive
privileges.
It should also be noted that,as indicated in Section 3-V of the existing Title V Operating Permit,
ACL shall not refuse entry or access to any authorized representative of the DAQ who requests
entry for purposes of inspection,and who presents appropriate credentials,nor will any person
obstruct,hamper,or interfere with any such authorized representative while in the process of
carrying out his official duties. Essentially,ACL understands that DAQ personnel who present
credentials and other documents as may be required by law will be allowed to:
• Enter the premises where the permitted facility is located or emissions-related activity is
conducted,or where records are kept under conditions of the permit;
• Have access to and copy,at reasonable times,any records that are required to be kept
under the conditions of the permit;
• Inspect at reasonable times and using reasonable safety practices any source,equipment
(including monitoring and air pollution control equipment),practices,or operations
regulated under the permit;and
• Sample or monitoring substances or parameters,using reasonable safety practices,for the
purpose of assuring compliance with the permit or applicable requirements at reasonable
times.
3.11 Annual Fee Payment and Emissions Inventory Requirements
In compliance with Section 3-W of the existing Title V Operating Permit,ACL shall pay all fees,
check or money order made payable to the N.C.Department of Environment and Natural
Resources,in accordance with 15A NCAC 2Q.0200. The annual permit fees shall refer to the
permit number.
Moreover,in accordance with Section 3-X of the existing Title V Operating Permit,ACL
personnel shall report by June 301 of each year the actual emissions of each air pollutant listed in
15A NCAC2Q.0207(a)from each emission source within the facility during the previous
calendar year. ACL shall report in or on such form as established by the Director and will be
certified by a Responsible Official. ACL satisfied this condition when the RY2020 Emissions for
ACL were uploaded to the Air Emissions Reporting On-line(AERO)database on June 3,2021
and followed-up with an RO Certification and back-up calculations on June 8,2021.
3.12 Confidential Information,Construction Permits,and Operating Permits
As stipulated in Section 3-Y of the existing Title V Operating Permit,ACL understands that all
requests for confidentiality must be submitted in accordance with 15A NCAC 2Q.0107.
Furthermore,ACL also understands that whenever confidential information is submitted pursuant
to 15A NCAC 2Q.0107,that a copy of all such information and the claim can be submitted
3-4

II
directly to the EPA. Please note that no confidentiality claims have been prepared during this
j monitoring period.
Pursuant to Section 3-Z of the existing Title V Operating Permit,ACL has an Air Construction
Permit and Title V Operating Permit in place.
3.13 Standard Application Form and Required Information
As stipulated in Section 3-AA of the existing Title V Operating Permit,ACL,when required,
shall submit applications and required information in accordance with the provisions of 15A
NCAC 2Q.0505 and 15A NCAC 2Q.0505.
3.14 Financial Responsibility and Compliance History
As stipulated in Section 3-BB of the existing Title V Operating Permit,ACL,understands that the
DAQ may require personnel to submit a statement of financial qualifications and/or statement of
substantial compliance history.
3.15 Refrigerant Requirements(Stratospheric Ozone and Climate Protection)
At this time,there are no appliances or refrigeration equipment, including air conditioning
equipment which use Class I or I1 ozone-depleting substances such as CFCs and HFCs listed as
refrigerants in 40 CFR 82 Subpart A(Appendices A and B). In the event that appliances or
refrigeration equipment that do meet the foregoing criteria are installed in the future,ACL
personnel,as indicated in Section CC of the existing permit shall perform the following tasks:
• Service,repair,and maintain such equipment according to the work practices,personnel
certification requirements,and certified recycling and recovery equipment specified in 40
CFR Part 82, Subpart F.
• ACL shall not knowingly vent or otherwise release any Class I or 11 substance into the
environment during the repair,servicing,maintenance,or disposal of any such device
except as provided in 40 CFR 82 Subpart F.
• ACL personnel shall comply with all reporting and recordkeeping requirements of 40
CFR 82.166. These reports shall be submitted to the EPA or its designee as required.
3.16 Prevention of Accidental Releases(Section 112r)
Section 3-DD of the existing Title V Operating permit addresses the development and registration
of a Risk Management Plan with the EPA pursuant to Section I I2r of the Clean Air Act. It
should also be noted that Section 3-EE of the existing Title V Operating permit indicates that
ACL has a general duty to take such steps as are necessary to prevent the accidental release of a
listed hazardous substance and minimize the consequences of the release if the facility produces,
processes,handles,or stores any amount of a listed hazardous substance. It should be noted that
ACL is not required to develop or register a Risk Management Plan with the EPA because it does
not store,produce,process,or handle any material listed in 40 CFR 68.130 in quantities that
surpass the threshold quantities of 40 CFR 68.115;therefore,Section 3-DD and Section 3-EE of
the existing Title V Operating permit are not applicable.
3-5

3.17 Title IV Allowances
Section 3-FF of the existing Title V Operating permit stipulates that the emissions from ACL
must not exceed any allowances that the facility lawfully holds under Title IV of the Federal
Clean Air Act. ACL is not subject to the requirements of Title IV;therefore,the requirements of
Section 3-FF are not applicable.
3.18 Air Pollution Emergency Episode
Should the DAQ Director declare an Air Pollution Emergency Episode,ACL will,in accordance
with Section 3-GG of the existing Title V Operating Permit, operate in accordance with the
previously approved Emission Reduction Plan or,in the absence of an approved plan,with the
appropriate requirements specified in 15A NCAC 2D.0300. ACL will comply with Section 3-
GG,when required.
3.19 Registration of Pollution Sources
In the event that the Director of the DAQ requires ACL to register a source of air pollution,the
registration and required information will be prepared in accordance with 15A NCAC 2D.0202(b)
to satisfy the requirements of Section 3-HH of the existing Title V Operating Permit.
3.20 Ambient Air Quality Standards
Pursuant to Section 3-II of the existing Title V Operating Permit,ACL has not operated in a
manner that would cause the ambient air quality standards in 15A NCAC 213.0400 to be exceeded
at any point beyond the facility premises.
3.21 General Emissions Testing and Reporting Requirements
When required,ACL personnel will provide test notifications and report submittals pursuant to
the applicable requirements of Section 3-JJ of the existing Title V Operating Permit.
3.22 Reopening For Cause
As indicated in Section 3-KK of the existing Title V Operating Permit,ACL understands that a
permit can be reopened and revised under the following circumstances:
• Additional requirements become applicable to a facility with a remaining permit term of
three(3)or more years;
• Additional requirements(including excess emissions requirements)become applicable to
a source covered by Title IV;
• The Director or EPA finds that the permit contains a material mistake or that inaccurate
statements were made in establishing the emission standards or other terms or conditions
of the permit;
• The Director of the EPA determines that the permit must be revised or revoked to assure
compliance with the applicable requirements.
3-6

ACL personnel also understand that an permit reopening shall be completed or revised permit
Y P g
issued within 18 months after the applicable requirement is promulgated.
3.23 Reporting Requirements for Non-Operating Equipment
Pursuant to Section 3-LL of the existing Title V Operating Permit,ACL has maintained a record
of operation for permitted equipment noting whenever the equipment was taken from and placed
into operation. Moreover,during operation,monitoring,record-keeping,and reporting
requirements,as prescribed by the permit,have been implemented within the monitoring period.
3.24 Fugitive Dust Control Requirements eats
Pursuant to Section 3-MM of the existing Title V Operating Permit,ACL has not caused or
allowed fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary.
3.25 Specific Permit Modifications
Section 3-NN of the existingTitle V Operating Permit addresses permit modifications. ACL has
P g
not prepared or submitted any permit modifications at this time;therefore, Section 3-NN is not
applicable.
3.26 Third-Party Participation and EPA Review
Section 3-00 of the existing Title V Operating Permit addresses permit modification subject to
45-Day review by the EPA. ACL understands that EPA's decision not to object to the proposed
permit is considered final and binding on the EPA and absent third-party petition,the failure to
P g P rtY
object is the end of EPA's decision-making process with respect to the revisions to the permit.
3-7