Exhibit_D_-_Skunk_Creek_LF_Non_Title_V_Air_Quality_Permit.pdf

Permitting Division

301 W. Jefferson St., Suite 410

Phoenix, Arizona 85003

P: 602-506-6010

E: AQmail@maricopa.gov

August 27, 2025

Joel Zurita

Environmental Quality Specialist

City of Phoenix

200 W Washington St, Floor 7

Phoenix, AZ 85003

The purpose of the letter is to inform you that the application for a permit renewal has been approved and will be incorporated into your air quality permit. The applicable permit conditions are enclosed with this letter.

If you need assistance with the permit, please contact the Business Assistance Coordinator office at 602-506-

5102. Email communications may be sent to AQPermits@maricopa.gov.

mailto:AQPermits@maricopa.gov

MARICOPA COUNTY AIR QUALITY DEPARTMENT

Permitting Division

301 W. Jefferson St., Suite 410, Phoenix, Arizona 85003

Phone: 602-506-6010 Fax: 602-506-6985

AIR QUALITY PERMIT TO OPERATE AND/OR CONSTRUCT

(As required by Title 49, Chapter 3, Article 2, Section 49-480, Arizona Revised Statutes)

ISSUED TO

Skunk Creek Landfill

3165 W Happy Valley Rd

Phoenix, AZ 85083

This air quality permit to operate and/or construct does not relieve the applicant of the responsibility of meeting all air pollution regulations.

THE PERMITTEE IS SUBJECT TO THE SPECIFIC AND GENERAL CONDITIONS IDENTIFIED IN THIS PERMIT.

FACILITY NUMBER: F001203 LEGACY PERMIT NUMBER: V97019

PERMIT NUMBER: P0012846 REVISION DATE: August 27, 2025

EXPIRATION DATE: July 31, 2030

TABLE OF CONTENTS

SPECIFIC CONDITIONS

1. Allowable Emissions:

2. Opacity

GASEOUS EMISSIONS

3. Air Pollution Prohibited:

4. Compliance Demonstration:

5. Compliance Plan:

6. Operation and Maintenance (O&M) Plan Requirements:

7. Recordkeeping:

CLOSED MUNICIPAL SOLID WASTE LANDFILLS

8. Controls:

9. Operational Requirements:

10. Performance Testing Requirements for Enclosed Flares

11. Compliance:

12. Monitoring of Operations:

13. Recordkeeping:

FUGITIVE DUST FROM DUST-GENERATING OPERATIONS

14. Applicability:

15. Exemptions:

16. Co-location

17. Dust Control Plan (DCP) Requirements:

18. Visible Emission Requirements for Dust-Generating Operations:

19. Exemptions from Dust-Generating Operation Opacity Limitation Requirement:

20. Stabilization Requirements for Dust-Generating Operations:

21. Soil Moisture:

22. Dust Control Training Classes for Dust-Generating Operations:

23. DCP Revisions

24. Recordkeeping:

25. Records Retention:

GENERAL CONDITIONS

26. Posting of Permit:

27. Compliance:

28. Malfunctions, Emergency Upsets, and Excess Emissions:

29. Revision / Reopening / Revocation:

30. Records:

31. Annual Emission Inventory Report:

32. Right to Entry:

33. Severability:

EQUIPMENT LIST

Skunk Creek Landfill Facility # F001203 Permit # P0012846 Revision Date: August 27, 2025

Maricopa County Air Quality Department Page 1 of 20

Any cited regulatory paragraphs or section numbers refer to the version of the rules and regulations that were in effect on the first date of public notice of the applicable permit condition unless specified otherwise. However, in the event the rules and regulations are amended during the term of this permit, the amended rules and regulations shall apply to this permit. Whenever the term “Control Officer” is used in this permit it shall be interpreted to mean “Control Officer or designated representative.” Where the term “Rule” appears, it shall be construed to mean “Maricopa County Air

Pollution Control Regulations” unless otherwise noted. Where the term “SIP Rule” appears, it shall be construed to mean “Maricopa County Air Pollution Control Regulations approved by the U.S. Environmental Protection Agency into the State Implementation Plan.”

SPECIFIC CONDITIONS

1. Allowable Emissions:

a. The Permittee shall not allow emissions into the atmosphere in excess of any of the following:

Twelve Month Rolling Total Emission Limits

(tons/yr)

Carbon Monoxide (CO) 17.12

Nitrogen Oxide (NOX) 14.52

Sulfur Oxides (SOX) 6.05

Total Hazardous Air Pollutants (HAPs) 17.47

Single HAP – Hydrochloric Acid (HCl) 8.99

b. The 12-month rolling total emissions shall be calculated monthly by the end of the following month by summing the emissions over the most recent 12 calendar months. The Permittee shall keep this emission record on-site for inspection or submittal upon request.

[SIP Rule 241 §§ 304, 305, 308]

2. Opacity

a. No person shall discharge into the ambient air from any single source of emissions any air contaminant, other than uncombined water, in excess of 20% opacity for a period aggregating more than three minutes in any 60-minute period.

[SIP Rule 300 § 301]

b. If any non-compliant visible emissions (excluding water vapor) are detected or reported, the Permittee shall determine the cause and/or the source of emissions. The Permittee shall then take immediate corrective action(s) and if necessary, shut down the applicable equipment. If visible emissions (excluding water vapor) exceed the above opacity standards subsequent to implementing corrective action(s), the

Permittee shall shut down the applicable equipment and institute repairs or changes necessary to ensure compliance prior to resuming operations.

[SIP Rule 241]

c. Compliance with the opacity requirement shall be determined by observations of visible emissions conducted in accordance with EPA Reference Method 9 as modified by EPA Reference Method 203B.

[SIP Rule 300 § 501]

GASEOUS EMISSIONS

3. Air Pollution Prohibited:

No person shall discharge from any source whatever into the atmosphere regulated air pollutants which exceed in quantity or concentration that specified and allowed in these rules, the Arizona Administrative Code

[A.A.C.] or Arizona Revised Statutes [A.R.S.], or which cause damage to property, or unreasonably interfere with the comfortable enjoyment of life or property of a substantial part of a community, or obscure visibility, Maricopa County Air Quality Department Page 2 of 20 or which in any way degrade the quality of the ambient air below the standards established by the Board Of

Supervisors or the Director.

[SIP Rule 100 § 301]

a. Limitation - Hydrogen Sulfide (H2S): No person shall emit H2S from any location in such a manner or amount that the concentration of such emissions into the ambient air at any occupied place beyond the premises on which the source is located exceeds 0.03 parts per million by volume (ppmv) for any averaging period of 30 minutes or more.

[Rule 320 § 304] [Locally Enforceable Only]

b. Material Containment Required: Materials including, but not limited to, solvents or other volatile compounds, paints, acids, alkalis, pesticides, fertilizer and manure shall be processed, stored, used and transported in such a manner and by such means that they will not unreasonably evaporate, leak, escape or be otherwise discharged into the ambient air in such quantities or concentrations as to cause air pollutions smells, aromas or stenches commonly recognized as offensive, obnoxious or objectionable to a substantial part of a community. Where means are available to effectively reduce the contribution to air pollution from evaporation, leakage or discharge, the installation and use of such control methods, devices or equipment shall be mandatory.

[Rule 320 § 302] [Locally Enforceable Only]

c. Reasonable Stack Height Required: Where a stack, vent or other outlet is at such a level that air contaminants are discharged to adjoining property, the Control Officer may require the installation of abatement equipment or the alteration of such stack, vent, or other outlet to a degree that will adequately dilute, reduce or eliminate the discharge of air contaminants to adjoining property.

[Rule 320 § 303] [Locally Enforceable Only]

4. Compliance Demonstration:

a. The Permittee shall perform a compliance demonstration by conducting a test to monitor H2S levels within 90 days of any of the following events:

i. The reception of a written request from the Control Officer.

b. The compliance demonstration shall be performed using a handheld air analyzer with a suitable range

(3.0 ppb – 10.0 ppm H2S).

c. The compliance demonstration shall be performed at a location representing the nearest occupied place beyond the premises on which the source of H2S is located.

d. The Permittee shall submit a report within 30 days of completion of each demonstration through the AQD

Online Portal. If the AQD Online Portal is not accessible, please contact the Control Officer for alternative means of submittal.

[SIP Rule 100 § 502]

5. Compliance Plan:

a. In the event of an exceedance of the H2S limitation, the Permittee shall submit a Compliance Plan to the

Control Officer, Attn: Compliance Manager, for approval. The Compliance Plan shall include:

i. Technological evaluation of additional odor control alternatives at the plant.

ii. Additional monitoring and/or air dispersion modeling to determine property line concentration of

H2S based on the implementation of selected odor control alternatives.

iii. Conceptual design and preliminary cost estimate for the proposed odor control alternatives.

iv. Schedule for design and construction of the proposed control alternatives.

v. Description of recommended actions.

Maricopa County Air Quality Department Page 3 of 20

b. The Permittee shall complete and submit the Compliance Plan within 120 days of exceeding the H2S emission limitation.

[SIP Rule 100 § 501] [SIP Rule 220 § 303]

6. Operation and Maintenance (O&M) Plan Requirements:

a. The Permittee shall comply with the most recently approved O&M Plan for the following devices. The

Permittee shall revise the O&M Plan upon the request of the Control Officer and whenever substantive changes are made to the equipment or plan, in accordance with department guidelines:

- LFG Collection System;

- LFG Control System (Flares, 4x); and

- Leachate/Condensate Collection System (drums, staging tanks, carbon adsorption – CAS).

b. The O&M Plan shall specify key system operating parameters, such as temperatures, pressures and/or flow rates, necessary to determine compliance and describe in detail procedures to maintain the approved emission control system. The Permittee shall monitor, operate, and maintain the equipment in accordance with the device’s approved O&M Plan. At a minimum the plan shall include:

i. Carbon Adsorption System: Adsorption temperature, desorption temperature, and effluent concentration.

ii. Flare: Combustion temperature, flow rate, and visible emissions.

c. Changes to an existing O&M Plan shall be made by submitting a complete, revised O&M Plan along with a cover letter identifying all changes and the reason for such changes. The Permittee may implement the changes addressed in the revised O&M plan after it submits the revision to the Control Officer. Unless disapproved in writing by the Control Officer, the Permittee shall continue to operate in accordance with the revised O&M plan.

d. If any control device is found to be operating outside a specified range, the Permittee shall immediately take corrective action to bring the device back into the specified operating range or shut down the device and the associated equipment vented to it.

e. If a pattern of excursions, as determined by the Control Officer or the Permittee, of operation outside the specified operating range develops, the Permittee shall submit for department approval a Corrective

Action Plan to bring the devices back into the specified operating range. The Plan shall be submitted to the Control Officer, Attn: Compliance Manager, within 30 days of the determination of the existence of excursions.

[SIP Rule 241]

7. Recordkeeping:

The Permittee shall keep the following records on site and available upon request. The records shall be retained for 5 years.

a. The Permittee shall maintain records of any process upsets that would cause the release of H2S or other waste gases into the atmosphere. Examples of such upsets would include failure of the blowers in the recirculation of gases in the aeration process or a catastrophic failure of the biological reactor responsible for H2S removal.

b. The Permittee shall retain all records pertaining to the repairs and schedules required to restore the treatment process after upset. The Permittee shall retain records of the operational parameter tests used to ensure proper operation of the process.

c. Monitoring and maintenance records specified in the O&M Plan:

i. Monitoring Records shall consist of an operations log sheet to be completed for every day the process and/or control device is in operation. Operations log sheets shall, at a minimum, contain

Maricopa County Air Quality Department Page 4 of 20 the following information: equipment identification; date and time of readings; identification of the individual recording the data; operating parameters to be monitored including units of measure, operating limits (upper and lower limits), and locations for recording measurements; measurement frequency; and if applicable, corrective action taken. An explanation shall be recorded for any periods of operation when the control device was not operating.

ii. Maintenance Records shall, at a minimum, contain the following information: equipment identification; date; identification of the individual performing the maintenance check; procedures to be performed including frequency of occurrence; results of inspection; and corrective action taken.

d. Whenever the O&M Plan requires that maintenance be performed, a record shall be made of the maintenance actions taken within 24 hours of maintenance completion.

e. Daily records of the O&M Plan's key system operating parameters. Account for any periods of operation when the control device was not operating.

f. An explanation shall be recorded for any scheduled maintenance that is not performed during the period designated in the O&M Plan.

[SIP Rule 100 §§ 501, 504]

CLOSED MUNICIPAL SOLID WASTE LANDFILLS

8. Controls:

a. The Permittee shall follow the requirements in Permit Condition 9 for operation of the landfill gas collection and control system (GCCS).

b. Landfill gas shall be exhausted to a fully functional flare at all times.

c. Flare Station 2 (Emission units FLR007 & FLR008) shall be operated as the primary control. Flare Station

1 (Emission units FLR005 & FLR 006) shall only be operated as a backup to Flare Station 2 during periods of maintenance or other unforeseen events that require rerouting of the landfill gas.

d. The combustion zone set-point temperature of the flares shall be greater than or equal to 1,400 ˚F.

e. The landfill gas flowrate to the flare shall not exceed the 1,320 standard cubic feet per minute (scfm) maximum flow rate of the enclosed flare.

f. The Permittee shall properly operate and maintain the flare for the control of landfill gas as specified in the Operation and Maintenance Plan.

[SIP Rule 241]

9. Operational Requirements:

The Permittee shall operate and maintain a GCCS that meets the following requirements:

a. The GCCS shall:

i. Be designed and operated to handle the expected gas flow rate;

ii. Contain extraction wells which shall be maintained in any number and spacing necessary to maintain emission and migration control and to collect gas from each area, cell, or group of cells in the landfill which are still generating gas as determined by measures of performance set forth in these conditions;

iii. Collect gas at a rate sufficient to maintain a negative pressure at all wellheads in the collection system without causing air infiltration, including any wellheads connected to the system as a result of expansion or excess surface emissions, for the life of the blower; and

iv. Be designed and operated to minimize off-site migration of subsurface gas and potential offsite impacts.

[Rule 321 § 302.1(a)] [Locally Enforceable Only]

Maricopa County Air Quality Department Page 5 of 20

b. All collected gas shall be routed to the following:

i. A control system designed and operated to reduce NMOC by 98 weight percent, or, when an enclosed combustion device is used for control, to either reduce NMOC by 98 weight percent or reduce the outlet NMOC concentration to less than 20 parts per million (ppm) by volume, dry basis as hexane at 3% oxygen. The reduction efficiency or ppm by volume must be established by an initial performance test to be completed no later than 180 days after the initial startup of the approved control system using the test methods specified in Permit Condition 10.a.

The control device must be operated within the parameter ranges established during the initial or most recent performance test. The operating parameters to be monitored are specified in

Subsection [c] of this permit condition.

[Rule 321 § 302.1(b)(2)] [Locally Enforceable Only]

ii. All emissions from any atmospheric vent from the gas treatment system are subject to the requirements of Subsection [b.i] of this permit condition. For purposes of these permit conditions, atmospheric vents located on the condensate storage tank are not part of the treatment system and are exempt from the requirements of Subsection [b.i] of this permit condition.

[Rule 321 § 302.1(b)(4)] [Locally Enforceable Only]

c. The GCCS shall be operated:

i. Within the parameter ranges established during the most recent performance test.

ii. With negative pressure at each wellhead except under the following conditions:

A fire or increased well temperature. The Permittee shall record instances when positive pressure occurs in efforts to avoid a fire.

Use of a geomembrane or synthetic cover. The Permittee shall develop acceptable pressure limits in the GCCS design plan.

A decommissioned well. The Permittee shall record any decommissioning of wells.

When the GCCS is not operating. The Permittee shall record instances when the GCCS is not operating or being used intermittently.

When using a passive venting system, as included in the approved GCCS design plan.

iii. At all times when the collected gas is routed to the control device.

iv. So that the methane concentration is less than 500 ppm above background at the surface of the landfill, as per the requirements and frequencies under Permit Condition 12.b. To determine if this level is exceeded, the Permittee must:

Conduct surface testing using an organic vapor analyzer, flame ionization detector, or other portable monitor meeting the compliance specifications in Permit Condition 11.b.

Conduct surface testing around the perimeter of the collection area and along a pattern that traverses the landfill at no more than 30-meter intervals and where visual observations indicate elevated concentrations of landfill gas, such as distressed vegetation and cracks or seeps in the cover and all cover penetrations which extend into the waste mass. Thus, the Permittee must monitor any openings that are within an area of the landfill where waste has been placed and a gas collection system is required. The Permittee may establish an alternative traversing pattern that ensures equivalent coverage.

Develop a surface monitoring plan to be included in the design plan that includes a topographical map with the monitoring route and the rationale for any site-specific deviations from the 30-meter intervals. Areas with steep slopes or other dangerous areas may be excluded from the surface testing.

Maricopa County Air Quality Department Page 6 of 20

d. The Permittee shall submit a revision to the most current GCCS design plan whenever a change is made to the GCCS.

[Rule 321 § 302.1] [Locally Enforceable Only]

10. Performance Testing Requirements for Enclosed Flares.

The Permittee shall conduct a performance test of the control system in accordance with Rule 270 and the provisions below:

a. The Permittee shall conduct performance tests on the following equipment according to the schedule stated in Subsection [c.ii] of this permit condition or within 60 days after the applicable equipment has achieved the capability to operate at its maximum production rate on a sustained basis. The testing deadline may be extended by the Control Officer for good cause, but in no case shall the testing deadline, including test report submittal, extend beyond 180 days after the permit issuance date or 180 days after the new applicable equipment has achieved the capability to operate at its maximum capacity, whichever occurs last.

i. Flare Station 2: Flares FS 2-1 & FS 2-2:

The Permittee shall measure the NMOC concentration in the flare inlet and outlet streams to demonstrate a minimum destruction efficiency of 98% by weight at a minimum combustion temperature of 1400 °F. The oxygen content of the outlet streams shall be recorded for correction of the NMOC concentration as hexane to 3% oxygen.

a) EPA Method 25, 25C, or 18 shall be used to determine compliance with the 98 weight percent efficiency or the 20 ppm by volume outlet concentration level requirement.

i) In cases where the outlet concentration is less than 50 ppm NMOC as carbon (8 ppm

NMOC as hexane), EPA Method 25A should be used in place of EPA Method 25.

ii) If using EPA Method 18, the minimum list of compounds to be tested shall be those published in the most recent Compilation of Air Pollutant Emission Factors (AP-42).

b) The following equation shall be used to calculate control efficiency:

Control Efficiency = (NMOCin − NMOCout)/(NMOCin)

Where, NMOCin = mass of NMOC entering control device

NMOCout = mass of NMOC exiting control device

c) EPA Method 3 or 3A shall be used to determine the oxygen content for correcting the

NMOC concentration as hexane to 3% oxygen. EPA Method 19 shall be used to determine the exhaust stream flowrate.

The Permittee shall measure the concentrations of NOx, CO, and HCl in the flare exhaust stream to demonstrate compliance with the emission limits specified in Permit Condition 1.a.

a) EPA Method 7E shall be used to determine emissions of NOx, EPA Method 10 shall be used to determine emissions of CO, EPA Method 26 or 26A shall be used to determine emissions of HCl.

The Permittee shall record the combustion chamber temperature and landfill gas flow rate during the performance test.

The NMOC emission rate for the landfill shall be calculated using the following equation:

MNMOC = (1.89 × 10−3) × QLFG × CNMOC

Where, MNMOC = mass emission rate of NMOC, megagrams per year

QLFG = flow rate of landfill gas, cubic meters per minute

Maricopa County Air Quality Department Page 7 of 20

CNMOC = NMOC concentration, ppm by volume as hexane

a) The flow rate of landfill gas, QLFG, shall be determined by measuring the total landfill gas flow rate at the common header pipe that leads to the control device using a gas flow measuring device calibrated according to the provisions of section 10 of EPA Method 2E or according to manufacturer recommendations.

b) The average NMOC concentration, CNMOC, shall be determined by collecting and analyzing landfill gas sampled from the common header pipe before the gas moving or condensate removal equipment using the procedures in EPA Methods 25C or 18. If using EPA Method

18, the minimum list of compounds to be tested shall be those published most recently in AP-42. The sample location on the common header pipe shall be before any condensate removal or other gas refining units. The Permittee shall divide the NMOC concentration from EPA Method 25C by six to convert from CNMOC as carbon to CNMOC as hexane.

ii. Flare Station 1: Flares FS 1-1 & FS 1-2:

The Permittee shall conduct performance tests on the flares in Flare Station 1 if it is used as a backup for equal to or greater than 120 consecutive hours and has not previously had a performance test in the last 5 years.

The Testing requirements shall be the same as those specified for Flare Station 2, except that testing for HCl is not required.

The performance test shall be done within 60 days after the applicable equipment has achieved the capability to operate at its maximum production rate on a sustained basis. The testing deadline may be extended by the Control Officer for good cause, but in no case shall the testing deadline, including test report submittal, extend beyond 180 days after the permit issuance date or 180 days after the new applicable equipment has achieved the capability to operate at its maximum capacity, whichever occurs last.

[Rule 270 § 310.1] [Rule 321 § 302.2] [Locally Enforceable Only]

b. If the Control Officer waives the performance test requirement due to a temporary suspension of operations in accordance with Rule 270, Section 402.4 the permittee must apply for a permit revision in accordance with Rule 220, Section 405. The permittee must also provide advance notification that the existing performance test requirement may not be met. These submittals must include a detailed description of the circumstances / reasons for the request and must be submitted immediately upon realizing the circumstances that necessitated the revision.

[SIP Rule 200 § 310.1] [Rule 270 § 401]

c. General performance test requirements:

i. Notice of Start-up: The Permittee shall notify the department within 14 days after a new applicable equipment has achieved the capability to operate at its maximum capacity. The notification shall be submitted through the AQD Online Portal and addressed to the attention of the Performance Test

Evaluation Supervisor.

[Rule 270 § 404.1] [Locally Enforceable Only]

ii. Subsequent performance tests shall be conducted every 5 years (no later than 62 months from the date of the previous test).

[SIP Rule 200 § 310.1] [Rule 270 § 401.2]

iii. Testing Criteria: Performance tests shall be conducted and data reduced in accordance with the test methods and procedures specified in the Test Methods section of this permit condition unless otherwise specified by the Control Officer. The Control Officer may specify or approve minor changes in methodology to a reference method, approve the use of an equivalent test method, approve the use of an alternative method that has been determined to be acceptable for

Maricopa County Air Quality Department Page 8 of 20 demonstrating compliance, or waive the requirement for performance tests because the Permittee has demonstrated by other means that the source is in compliance with the standard.

iv. Test Methods: Sampling sites and velocity traverse points shall be selected in accordance with EPA

Test Method 1or 1A. The gas volumetric flow rate shall be measured in accordance with EPA Test

Method 2, 2A, 2C, 2D, 2F, 2G or 19. The dry molecular weight shall be determined in accordance with

EPA Test Method 3, 3A or 3B. The stack gas moisture shall be determined in accordance with EPA

Test Method 4. These methods must be performed, as applicable, during each test run.

[Rule 270 § 301.1] [Locally Enforceable Only]

v. Testing Conditions: Performance tests shall be conducted under representative operating conditions and all equipment shall be operated during testing in accordance with the most recently approved O&M Plan or according to its operations manual if no O&M Plan is required. The Permittee shall make available to the Control Officer any records necessary to determine appropriate conditions for performance tests. Operations during periods of startup, shutdown, and equipment malfunction shall not constitute representative conditions for performance tests unless otherwise specified in the applicable standard or permit conditions.

[Rule 270 § 301.4] [Locally Enforceable Only]

vi. Monitoring Requirements: The Permittee shall record all process and control equipment information that are necessary to document operating conditions during the test and explain why the conditions represent normal operation. Operational parameters shall be monitored and recorded at least once every 30 minutes during each of the required test runs and documented in the test report. The operational parameters monitored shall be capable of indicating that the equipment is operating within the permitted limits, both during and after the performance tests.

[Rule 270 § 301.6(c)] [Locally Enforceable Only]

vii. Test Protocol Submittal: The Permittee shall submit a separate test protocol for each performance test to the Control Officer for review and approval at least 30 days prior to each performance test unless otherwise specified in the applicable standard or in this permit. The test protocol shall be prepared in accordance with the most recent version of the department’s “Air Quality Performance

Test Guidelines for Compliance Determination in Maricopa County.” A completed copy of the department’s “Test Protocol Submittal Form” shall accompany each test protocol.

[Rule 270 § 403] [Locally Enforceable Only]

viii. Chain of Custody: The chain of custody procedures in ASTM D4840-99 “Standard Guide for

Sampling Chain-of-Custody Procedures” shall be followed for all samples.

[Rule 270 § 301.2] [Locally Enforceable Only]

ix. Sample Handling: Procedures in ASTM D6911-15 “Standard Guide for Packaging and Shipping

Environmental Samples for Laboratory Analysis” (incorporated by reference-see 40 CFR 60.17) shall be followed for all samples, where appropriate.

[Rule 270 § 301.2] [Locally Enforceable Only]

x. Notice of Testing: The Permittee shall notify the Control Officer in writing at least two weeks in advance of the actual date and time of each performance test so that the Control Officer may have a representative attend.

[Rule 270 § 404.2] [Locally Enforceable Only]

xi. Testing Facilities Required: The Permittee shall install any and all sample ports or platforms necessary to conduct the performance tests, provide safe access to any platforms, and provide the necessary utilities for testing equipment.

[Rule 270 § 301.5] [SIP Rule 42]

xii. Minimum Testing Requirements: Each performance test shall consist of three separate test runs with each test run being at least one hour in duration unless otherwise specified in the applicable standard or in this permit. The same test methods shall be used simultaneously for both the inlet

Maricopa County Air Quality Department Page 9 of 20 and outlet measurements, if applicable, or justification for any necessary exceptions shall be provided in the test protocol. Emissions rates, concentrations, grain loadings, and/or efficiencies shall be determined as the arithmetic average of the values determined for each individual test run.

Performance tests may only be stopped for good cause, which includes forced shutdown, failure of an irreplaceable portion of the sample train, extreme meteorological conditions, or other circumstances beyond the Permittee’s control. Termination of a performance test without good cause after the first test run has commenced shall constitute a failure of the performance test.

[Rule 270 § 301.6] [Locally Enforceable Only]

xiii. Test Report Submittal: The Permittee shall complete and submit a separate test report for each performance test to the Control Officer within 45 days after the completion of testing unless otherwise specified in the applicable standard or in this permit. The test report shall be prepared in accordance with the most recent version of the department’s “Air Quality Performance Test

Guidelines for Compliance Determination in Maricopa County.” A completed copy of the department’s “Test Report Submittal Form” shall accompany each test report.

[Rule 270 § 405.3] [Locally Enforceable Only]

xiv. Compliance with allowable emission limits and standards shall be determined by the performance tests specified in this permit. If test results do not demonstrate compliance with the requirements of these permit conditions, the Permittee shall make the necessary repairs and/or adjustments to the equipment and demonstrate compliance through retesting. In lieu of retesting, the Permittee may be able to submit an application for a permit revision to establish operational limitations or allowable emission limits based on the equipment’s actual performance. Neither option will nullify the fact that test results did not demonstrate compliance with the requirements of the permit conditions or nullify any violations that may result from this noncompliance. In addition to compliance demonstrations, test results shall be used for annual emissions inventory purposes if the Permittee is required to complete an emissions inventory survey.

[SIP Rule 200 § 310.1]

xv. Correspondence: All test extension requests, test protocols, test date notifications, and test reports required by this permit shall be submitted to the Control Officer using the AQD Online Portal and addressed to the attention of the Performance Test Evaluation Supervisor.

[SIP Rule 220 § 308] [Locally Enforceable Only]

xvi. Authority: The above testing requirements represent the minimum level of testing to monitor for compliance with the emission limits in this permit. Nothing in this section shall prevent the Control

Officer from requiring additional performance testing as deemed necessary to ensure permit compliance and protection of the public health and welfare.

[SIP Rule 200 § 310.1] [Rule 270 § 103]

11. Compliance:

a. The following procedures must be used for compliance with the GCCS operational requirements as provided in Permit Condition 9:

i. Actual flow data may be used instead of, or in conjunction with, the equations below to project the expected gas generation flow rate:

For sites with unknown year-to-year solid waste acceptance rate:

Qm = 2LOR × (e−kc – e−kt)

Where, Qm = Maximum expected gas generation flow rate, cubic meters per year

LO = Methane generation potential, cubic meters per megagram solid waste

R = Average annual acceptance rate, megagrams per year

Maricopa County Air Quality Department Page 10 of 20 k = Methane generation rate constant, year−1 t = Age of the landfill at equipment installation plus the time the Permittee intends to use the gas mover equipment or active life of the landfill, whichever is less. If the equipment is installed after closure, t is the age of the landfill at installation, years c = Time since closure, years (for an active landfill c = 0 and e−kt = 1)

For sites with known year-to-year solid waste acceptance rate:

QM = ∑ 𝑛

𝑖=0 2kLOMi × (e−kti)

Where, QM = Maximum expected gas generation flow rate, cubic meters per year k = Methane generation rate constant, year−1

LO = Methane generation potential, cubic meters per megagram solid waste

Mi = Mass of solid waste in the ith section, megagrams ti = Age of the ith section, years

ii. For the purposes of determining sufficient density of gas collectors, the Permittee shall maintain a system of vertical wells, horizontal collectors, or other collection devices consistent with the approved GCCS design plan, capable of controlling and extracting gas from all portions of the landfill sufficient to meet all operational and performance standards.

iii. The provisions of these conditions apply at all times that the GCCS is in operation. The gas mover system must be shut down and all valves in the collection and control system contributing to venting of the gas to the atmosphere must be closed within one hour of the collection or control system not operating.

[Rule 321 § 302.3] [Locally Enforceable Only]

b. The following procedures must be used for compliance with the surface methane operational requirements as provided in Permit Condition 9 and frequencies as provided in Permit Condition 12.b:

i. After startup of the GCCS, the Permittee must monitor surface concentrations of methane along the entire perimeter of the collection area and along a pattern that traverses the landfill at no more than

30-meter intervals (or a site-specific established spacing) for each collection area on an annual basis using an organic vapor analyzer, flame ionization detector, or other portable monitor meeting the specifications provided in subsection [vi] of this section, or through the use of alternative technologies if approved by the Control Officer.

ii. The background concentration must be determined by moving the probe inlet upwind and downwind outside the boundary of the landfill at a distance of at least 30 meters from the perimeter wells.

iii. Surface emission monitoring must be performed in accordance with EPA Method 21, except that the probe inlet must be placed within 5 to 10 centimeters of the ground. Monitoring must be performed during typical meteorological conditions.

iv. Any reading of 500 ppm or more above background at any location must be recorded as a monitored exceedance and the below actions must be taken. As long as the specified actions are taken, the exceedance is not a violation of the operational requirements of Permit Condition 9:

The location of each monitored exceedance must be marked and the location and concentration recorded. Location shall be recorded as latitude and longitude coordinates using an instrument with an accuracy of at least four meters. The coordinates must be in decimal degrees with at least five decimal places.

Maricopa County Air Quality Department Page 11 of 20

Cover maintenance or adjustments to the vacuum of the adjacent wells to increase the gas collection in the vicinity of each exceedance must be made and the location must be re-monitored within 10 calendar days of detecting the exceedance.

If the re-monitoring of the location shows a second exceedance, additional corrective action must be taken and the location must be monitored again within 10 days of the second exceedance. If the re-monitoring shows a third exceedance for the same location, the action specified in subsection 5) of this section must be taken, and no further monitoring of that location is required until the action specified in subsection 5) of this section has been taken.

Any location that initially showed an exceedance but has a methane concentration less than

500 ppm methane above background at the 10-day re-monitoring specified in subsection 2) or

3) of this section must be re-monitored one month from the initial exceedance. If the one-month re-monitoring shows a concentration less than 500 ppm above background, no further monitoring of that location is required until the next annual monitoring period. If the one-month re-monitoring shows an exceedance, the actions specified in subsection 3) or 5) of this section must be taken.

For any location where monitored methane concentration equals or exceeds 500 ppm above background 3 times within an annual period, a new well or other collection device must be installed within 120 calendar days of the initial exceedance. An alternative remedy to the exceedance, such as upgrading the blower, header pipes or control device, and a corresponding timeline for installation may be submitted to the Control Officer for approval.

v. The Permittee must implement a program to monitor for cover integrity and implement cover repairs as necessary on an annual basis. If there are no cover issues identified for three consecutive annual monitoring periods, then the Permittee may stop monitoring for cover integrity, except after extreme weather events. In the case of extreme weather events, such as receiving 1 inch or more of rain over any 24-hour period as measured from the nearest Flood Control District of Maricopa County rain gauge, all necessary cover repairs must be made as soon as practical.

vi. In order to comply with the provisions in this section, the Permittee must comply with the following instrumentation specifications and procedures for surface emission monitoring devices:

The portable analyzer must meet the instrument specifications provided in section 6 of EPA

Method 21, except that “methane” replaces all references to “VOC”.

The calibration gas must be methane, diluted to a nominal concentration of 500 ppm in air.

To meet the performance evaluation requirements in section 8.1 of EPA Method 21, the instrument evaluation procedures of section 8.1 of EPA Method 21 must be used.

The calibration procedures provided in sections 8 and 10 of EPA Method 21 must be followed immediately before commencing a surface monitoring survey.

[Rule 321 § 302.3] [Locally Enforceable Only]

12. Monitoring of Operations:

The Permittee shall monitor landfill operations by complying with the following requirements:

a. The enclosed flares shall be installed, calibrated, maintained, and operated according to the manufacturer's specifications, including the following equipment:

i. A temperature monitoring device equipped with a continuous recorder and having a minimum accuracy of +/- 1% of the temperature being measured expressed in degrees Celsius or +/- 0.5 degrees Celsius, whichever is greater. A temperature monitoring device is not required for boilers or process heaters with design heat input capacity equal to or greater than 44 megawatts.

ii. A device that records flow to, or bypass of, the control device. The Permittee shall either:

Maricopa County Air Quality Department Page 12 of 20

Install, calibrate, and maintain a gas flow rate measuring device that shall record the flow to the control device at least every 15 minutes; or

If equipped, secure the bypass line valve in the closed position with a car-seal or a lock-and-key type configuration. A visual inspection of the seal or closure mechanism shall be performed at least once every month to ensure that the valve is maintained in the closed position and that the gas flow is not diverted through the bypass line.

b. In order to demonstrate compliance with the 500 ppm surface methane operational standard in Permit

Condition 9, the Permittee must monitor surface concentrations of methane according to the compliance procedures and instrument specifications provided in Permit Condition 11. In addition:

i. Any methane reading of 500 ppm or more above background detected during the annual monitoring returns the frequency for that landfill to quarterly monitoring.

ii. Any closed landfill that has had no monitored exceedances of the operational standard in three consecutive years may stop monitoring surface methane emissions.

[Rule 321 § 302.4] [Locally Enforceable Only]

13. Recordkeeping:

The Permittee shall maintain the following records and make them available to the Control Officer upon request. Records shall be retained for five years, except for the GCCS design plan which shall be kept and made available to the Control Officer upon request while the GCCS is in use.

a. A GCCS design plan that meets the design requirements in 40 CFR 60.33f(b) and 40 CFR 60.33f(c).

i. The GCCS design plan must include any alternatives to the operational standards, test methods, procedures, compliance measures, monitoring, recordkeeping, or reporting provisions of these conditions proposed by the Permittee.

ii. The GCCS design plan must either conform to specifications for active collection systems in 40 CFR

60.40f or include a demonstration to the Control Officer’s satisfaction of the sufficiency of the alternative provisions to 40 CFR 60.40f.

iii. The Permittee shall maintain records of all GCCS control device’s maintenance (including the date when maintenance was performed and the maintenance procedures that were performed). In addition, one of the following documents shall be available at all times at the facility where the GCCS control device is located:

The manufacturer’s written instructions for operation and maintenance of the GCCS control device; or

A written maintenance schedule.

b. Records of subsequent tests or monitoring shall be maintained for a minimum of five years.

c. Records of the control device vendor specifications shall be maintained until removal of that control device.

d. A record of the enclosed flare temperature recorded at least every 15 minutes by a continuous temperature recorder.

e. Records of the landfill gas flowrate to the flare.

f. Records of any cover integrity monitoring and repair, as described in Permit Condition 11.b.v.

g. Records of any instance of wellhead positive pressure or insufficient pressure.

h. Description and duration of all periods when the GCCS was not operating and length of time the GCCS was not operating, including periods of intermittent use of the GCCS.

i. The calculation methodology used to estimate current emissions.

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j. A schedule for the replacement of the carbon canisters and any filter replacement for the leachate/condensate collection system, if applicable.

k. Records of the location of each exceedance of the 500 ppm methane concentration as provided in Permit

Condition 11 and the concentration recorded at each location for which an exceedance was recorded in the previous month. Location shall be recorded as latitude and longitude coordinates using an instrument with an accuracy of at least four meters. The coordinates must be in decimal degrees with at least five decimal places.

l. Records of any wells that have been decommissioned.

m. Records of any supplemental fuel used in the operation of the GCCS.

n. An up-to-date plot map showing each existing and planned collector in the system and providing a unique identification location label for each collector.

o. Records of the installation date and location of all newly installed collectors.

[Rule 321 § 302.5] [Locally Enforceable Only]

FUGITIVE DUST FROM DUST-GENERATING OPERATIONS

14. Applicability:

a. The provisions of this permit section apply to all dust-generating operations except for those dust-generating operations listed in Permit Condition 15 below. Any person engaged in a dust-generating operation subject to this permit section shall be subject to the standards and/or requirements of this permit section before, after, and while conducting such dust-generating operation, including during weekends, after work hours, and on holidays.

b. For the purpose of Rule 310, any control measure that is implemented must achieve the applicable standard(s) described in Rule 310, as determined by the corresponding test method(s), as applicable, and must achieve other applicable standard(s) set forth in Rule 310.

c. Regardless of whether a dust-generating operation is in compliance with an approved Dust Control Plan

(DCP) or there is no approved DCP, the owner and/or operator of a dust-generating operation shall be subject to all requirements of Rule 310 at all times.

d. Failure to comply with the provisions of these requirements, as applicable, and/or of an approved DCP, shall constitute a violation.

[SIP Rule 310 §§ 102, 301]

15. Exemptions:

The provisions of this permit section shall not apply to the following activities:

a. Emergency activities that may disturb the soil conducted by any utility or government agency in order to prevent public injury or to restore critical utilities to functional status.

b. Establishing of initial landscapes without the use of mechanized equipment or conducting landscape maintenance without the use of mechanized equipment. However, establishing initial landscapes without the use of mechanized equipment and conducting landscape maintenance without the use of mechanized equipment shall not include grading or trenching performed to establish initial landscapes or to redesign existing landscapes.

[SIP Rule 310 § 103]

16. Co-location

The Permittee shall not co-locate any crushing & screening, hot mix asphalt plant and/or concrete batch facilities with the equipment covered by this permit as documented in the equipment list. Co-located sources are those located on contiguous or adjacent properties, which are under common control of the Permittee.

[SIP Rule 100 § 200.27] [SIP Rule 241]

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17. Dust Control Plan (DCP) Requirements:

a. The Permittee shall comply with the most recently approved DCP and the provisions of MCAQD Rule 310

Sections 301 through 310 at all times.

[SIP Rule 310 §§ 301-310]

b. The DCP shall be kept available onsite at all times.

[SIP Rule 310 § 409]

18. Visible Emission Requirements for Dust-Generating Operations:

a. The Permittee shall not cause or allow visible fugitive dust emissions to exceed 20% opacity.

b. The Permittee shall not cause or allow visible emissions of particulate matter, including fugitive dust, beyond the property line within which the emissions are generated. Visible emissions shall be determined by a standard of no visible emissions exceeding 30 seconds in duration in any six-minute period as determined by using EPA Reference Method 22. This requirement does not apply to dust-generating operations conducted within 25 feet of the property line.

[SIP Rule 310 § 303.1]

19. Exemptions from Dust-Generating Operation Opacity Limitation Requirement:

a. If wind conditions cause fugitive dust emissions to exceed the opacity requirements in this permit, despite implementation of the DCP, an owner and/or operator shall:

i. Ensure that all control measures and requirements of the DCP are implemented and the subject violations cannot be prevented by better application, operation, or maintenance of these measures and requirements.

ii. Cease dust-generating operations and stabilize any disturbed surface area consistent with the

Stabilization Requirements of these permit conditions.

iii. Compile records consistent with the recordkeeping requirements of these permit conditions and document the control measure and other DCP requirements implemented.

b. Emergency Maintenance of Flood Control Channels and Water Retention Basins: The opacity limit shall not apply to emergency maintenance of flood control channels and water retention basins, provided that control measures are implemented.

[SIP Rule 310 § 303.2]

20. Stabilization Requirements for Dust-Generating Operations:

a. Unpaved Parking Lot: The owner and/or operator of any unpaved parking lot shall not allow visible fugitive dust emissions to exceed 20% opacity and shall not allow silt loading equal to or greater than 0.33 oz/ft

However, if silt loading is equal to or greater than 0.33 oz/ft , then the owner and/or operator shall not allow the silt content to exceed 8%. An unpaved parking lot includes any area that is not paved and that is used for parking, maneuvering, material handling, or storing motor vehicles and equipment.

[SIP Rule 310 §§ 232, 304.1]

b. Unpaved Haul/Access Road:

An unpaved haul/access road includes any on-site road or equipment path that is not paved and is used by commercial, industrial, institutional, and/or governmental traffic.

i. The owner and/or operator of any unpaved haul/access road (whether at a work site that is under…