Exhibit_E_-_19th_Ave_F002388_2021_NTV_MCAQD.pdf

3800 N. Central Avenue, Suite 1400 | Phoenix, AZ 85012

Permitting Division Phone: 602.506.6010 Fax: 602.506.6985

Maricopa.gov/AQ CleanAirMakeMore.com

City of Phoenix Public Works Department ATTN: Doug Sawyer 3060 S 27th Avenue Phoenix, AZ 85009

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 Small Business Assistance Coordinator office at

602.506.5102 or contact the undersigned at 602.506.7248. Email communications may be sent to AQPermits@maricopa.gov.

mailto:AQPermits@maricopa.gov

MARICOPA COUNTY AIR QUALITY DEPARTMENT

Engineering and Permitting Division

3800 N. Central Avenue, Suite 1400, Phoenix, Arizona 85012 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

City of Phoenix - 19TH Avenue Landfill 1701 W Lower Buckeye Rd

Phoenix, AZ 85007

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: F002388 LEGACY PERMIT NUMBER: 010048

PERMIT NUMBER: P0008537 REVISION DATE: 10/26/2021

EXPIRATION DATE: 08/31/2026

Todd Martin, Non-Title V Permit Supervisor

TABLE OF CONTENTS

SPECIFIC CONDITIONS

SITE-WIDE CONDITIONS

1. Allowable Emissions:

2. Opacity:

ODORS and GASEOUS EMISSIONS

3. Air Pollution Prohibited:

4. Compliance Demonstration:

5. Compliance Plan:

6. Recordkeeping:

LANDFILL GAS (LFG) CONTROLS – GENERAL

7. Controls:

8. Operations and Maintenance (O&M) Plans:

9. Monitoring:

10. Recordkeeping:

LFG CONTROLS – ENCLOSED FLARE at CELL A

11. Controls:

12. Performance Testing and Compliance Demonstration for Enclosed Flare:

LFG CONTROLS – CARBON ADSORPTION at CELL A-1

13. Controls:

14. Vapor Sampling Requirements (Grab Sampling and Method 25C):

RULE 310: FUGITIVE DUST from DUST-GENERATING OPERATIONS

15. Applicability:

16. Exemptions:

17. Co-location

18. Dust Control Plan Requirements:

19. Visible Emission Requirements for Dust-Generating Operations:

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

21. Stabilization Requirements for Dust-Generating Operations:

22. Soil Moisture:

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

24. Dust Control Plan Revisions

25. Recordkeeping:

26. Records Retention:

GENERAL CONDITIONS

27. Posting of Permit:

28. Compliance:

29. Malfunctions, Emergency Upsets, and Excess Emissions:

30. Revision / Reopening / Revocation:

31. Records:

32. Right to Entry:

33. Severability:

City of Phoenix 19th Ave Landfill F002388_P0008537 Revision Date: 10/26/2021

Maricopa County Air Quality Department Page 1 of 15

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.

SPECIFIC CONDITIONS

SITE-WIDE CONDITIONS

1. Allowable Emissions:

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

Pollutant

12 Month Rolling Total

Emission Limits Volatile Organic Compounds (VOC) 4,000 pounds Nitrogen Oxide (NOx) 3,690 pounds Carbon Monoxide (CO) 4,352 pounds Particulate Matter (PM10/ PM2.5) 1,419 pounds Total Hazardous Air Pollutants (HAPs) 156 pounds

The 12-month rolling total emissions shall be calculated monthly within 15 days following the end of each calendar month by summing the emissions over the most recent 12 calendar months. The Permittee shall keep this emission report on-site for inspection or submittal upon request.

[Rule 220 §302.2]

2. Opacity:

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.

[Rule 300 §301] [Locally Enforceable Only]

a. 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.

[Rule 220 §302.2] [Locally Enforceable Only]

b. Opacity shall be determined by observations of visible emissions conducted in accordance with EPA Reference Method 9 as modified by EPA Reference Method 203B.

[Rule 300 §501] [SIP Rule 25.C]

ODORS and 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 [AAC] or Arizona Revised Statutes [ARS], 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, 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

Maricopa County Air Quality Department Page 2 of 15 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] [SIP Rule 32.E]

b. Emission Control System (ECS) Required:

i. If needed to meet the H2S limitation in Subsection 3.a, above, the Permittee shall vent sulfurous gases, vapors and gas entrained effluents without bypass to a control system capable of removing sulfurous compounds. Typical controls which qualify include:

1) Wet or packed bed scrubbers;

2) Use of chemical deodorizers such as sodium hydroxide or sodium hypochlorite;

3) Carbon adsorption systems.

ii. The Permittee shall properly install, operate, and maintain in calibration and in good working order, devices for indicating temperatures, pressures, transfer rates, rates of flow, or other operating conditions necessary to determine if the required ECS is functioning properly and is properly maintained as described in an approved Operation and Maintenance (O&M) Plan, in accordance with Permit Condition Error! Reference source not found..

[Rule 320 §304][SIP Rule 32.E]

c. 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 reduce effectively 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] [SIP Rule 32.C]

d. 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] [SIP Rule 32.D]

4. Compliance Demonstration:

a. The Permittee shall perform a compliance demonstration by conducting a test to monitor H2S levels within 90 days of 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.

[Rule 320 §304] [Locally Enforceable Only]

d. The Permittee shall submit a report within 30 days of completion of the demonstration to the Control Officer, Attn: Compliance Division Manager that details the results of each compliance demonstration.

[SIP Rule 220 §302.4]

5. Compliance Plan:

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:

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

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b. Additional monitoring and/or air dispersion modeling to determine property line concentration of H2S based on the implementation of selected odor control alternatives.

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

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

e. Description of recommended actions.

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

[SIP Rule 220 §303]

6. 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.

[SIP Rule 220 §§302.7, 500] [SIP Rule 100 §504]

LANDFILL GAS (LFG) CONTROLS – GENERAL

7. Controls:

Filter/Condensate Knockout Drums with Small Carbon Canisters:

a. All landfill gas (LFG) collected by the field gas collection system (GCCS) shall be routed through the filter/condensate knockout drums having a minimum control efficiency of 99.7% by weight for particulate matter less than 5 microns or above, as certified by the filter manufacturer.

b. Condensate knock out drums and canisters shall be exhausted at all times to either the Cell A flare or the Cell A-1 Carbon Adsorption System (CAS) at all times during operation.

c. Condensate knock out drums and canisters shall be included in the O&M Plan as described in Permit Condition 8.

[Rule 220 §302.2, and §302.16]

8. Operations and Maintenance (O&M) Plans:

Flare at Cell A and CAS, Cell A-1:

a. The Permittee shall follow the approved O&M Plan for the flare at Cell A, and CAS at Cell A-1.

b. The Permittee shall comply with the approved O&M Plan. The Permittee shall revise the O&M Plan upon the request of the Department and whenever substantive changes are made to the equipment or plan, in accordance with the Department guidelines.

c. 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 and flow meter(s). The Permittee shall monitor, operate and maintain the equipment in accordance with the device’s approved O&M Plan.

d. 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.

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e. 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.

f. If a pattern of excursions of operation outside the specified operating range develops, as determined by the Control Officer or the Permittee, the Permittee shall submit to the Control Officer for 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 Division Manager, within 30 days of the determination of the existence of excursions.

[Rule 220 §302.4] [Locally Enforceable Only]

9. Monitoring:

The Permittee shall install and maintain flow rate measurement devices on the inlet stream to the flare and CAS and continuously record the total flow rate in actual cubic feet per minute (acfm).

[Rule 220 §302.4] [SIP Rule 41]

10. Recordkeeping:

The Permittee shall maintain the following records for a period of at least five years from the date of the records and make them available to the Control Officer upon request:

a. Hours of operation of the flare,

b. Continuous records of the flow rate of LFG to the Flare and CAS as well as accurate and current total LFG generation rate.

c. Continuous combustion temperature of the flare as recorded by a continuous temperature recorder,

d. Records of the position of each GAC tank in series (first, second, or third stage position, etc…), and the date each are removed from service and returned to service and/or dates of media replacement.

e. Hours of operation of active venting.

f. A schedule for the replacement of the carbon canisters and any filter replacement.

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

i. Monitoring Records shall consist of an operations log sheet to be completed in accordance with the most recently approved O&M Plan, while the process and/or control device is in operation.

Operations log sheets shall, at a minimum, contain 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. Account 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 (acceptable, nozzle plugged, belt cracked, etc.); and corrective action taken (none, cleaned nozzle, replace belt, etc.)

iii. 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.

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

[Rule 220 §302.7]

LFG CONTROLS – ENCLOSED FLARE at CELL A

11. Controls:

ENCLOSED FLARE at CELL A:

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PERENNIAL ENERGY INC.

9.00 MMBTU/hr

a. LFG generated at Cell A shall be captured and routed at all times to the flare system for the control of LFG non-methane organic compound (NMOC) emissions and hazardous air pollutants (HAPs).

b. Proper operation shall be construed as the flare having at least a 98% destruction efficiency by weight for NMOCs or reduce the outlet NMOC concentration to less than 20 parts per million by volume, dry basis as hexane at 3 percent oxygen as demonstrated by testing and analysis as conducted per Permit Condition 12.

c. The flare shall be set to operate at a combustion chamber set point temperature of either 1400° F, or the set point temperature established during the most recent, successful performance test.

d. The flare shall have a maximum LFG inlet stream of 600 scfm.

[Rule 220 §302.2, and §302.16]

e. The flare shall be maintained and operated in accordance with the approved O&M Plan specified in Permit Condition 8.

[Rule 320 §302] [SIP Rule 32.C]

12. Performance Testing and Compliance Demonstration for Enclosed Flare:

** Note: Flare testing for this site was last performed in 2016 and is required to be performed again as identified in Permit Condition 12.b **

a. Testing Requirements: The Permittee shall conduct performance testing on the 18.00 MMBtu/hr | 1,500 scfm enclosed flare or the 9.00 MMBtu/hr | 600 scfm enclosed flare (whichever is in operation when 5-year scheduled performance test is due as per Permit Condition 12.b) to demonstrate compliance with the NMOC destruction efficiency required by Permit Condition 11.a. The test shall be conducted within 60 days after the issuance date of this permit, or within 60 days after this new flare has achieved the capability to operate at its maximum production rate on a sustained basis, whichever occurs last. 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.

[County Rule 200 §310.1] [County Rule 270 §401] [SIP Rule 27 §A]

i. Compliance Demonstration for Enclosed Flare:

1) The Permittee shall measure the NMOC concentrations in the flare inlet and exhaust streams to demonstrate compliance with either the minimum NMOC destruction efficiency requirement or the maximum outlet NMOC concentration. Testing shall also demonstrate compliance with all applicable VOC emission limits of these permit conditions.

2) The Permittee shall measure the concentrations of NOx and CO in the flare exhaust stream.

Testing shall demonstrate compliance with all applicable NOx and CO concentrations and/or emission limits of these permit conditions.

3) The Permittee shall determine the volumetric flow rate and dry molecular weight of the gas streams in order to perform the necessary calculations.

4) Testing shall also demonstrate compliance with applicable VOC emission limits of these permit conditions (assume 85% of NMOC are VOC).

[County Rule 200 §309] [County Rule 321 §301] [County Rule 360 §301.88] [Arizona Testing Manual for Air Pollutant Emissions] [40 CFR §60.752(b)]

b. The Permittee shall conduct a performance test on the Cell A flare between August 26, 2021 and December 24, 2021. Subsequent tests shall be performed every 5 years (within 58 to 62 months of the previous test).

[County Rule 200 §310]

c. Testing Criteria: Performance tests shall be conducted and data reduced in accordance with the test

Maricopa County Air Quality Department Page 6 of 15 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 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.

[County Rule 270 §§301.1, 301.2] [SIP Rule 27 §B]

d. 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.

i. VOC testing shall be conducted in accordance with EPA Test Method 25, 25C or 18. In cases where the outlet concentration is less than 50 ppm as carbon (8 ppm as hexane), EPA Test Method 25A should be used in place of EPA Test Method 25. If using EPA Test 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).

ii. NOx testing shall be conducted in accordance with EPA Test Method 7E.

iii. CO testing shall be conducted in accordance with EPA Test Method 10.

iv. EPA Test Method 3 or 3A shall be used to determine the O2 content for correcting the NMOC concentration as hexane to 3 percent O2. EPA Test Method 19 shall be used to determine the exhaust stream flowrate.

[County Rule 321 §301] [County Rule 360 §301.88] [40 CFR §60.754(d)]

v. If the flare is equipped with condensate injection, the Permittee shall conduct two separate performance tests of the flare under the following two operating scenarios: Representative operating conditions with condensate injection and representative operating conditions without condensate injection.

vi. The Permittee shall record the combustion chamber temperature and LFG flow rate during the performance test.

[County Rule 321 §301] [County Rule 360 §301.88] [40 CFR §60.756(b)]

e. Operating 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.

[County Rule 270 §403]

f. 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.

[County Rule 270 §301.1] [SIP Rule 27 §B]

g. Test Protocol Submittal: The Permittee shall submit a separate test protocol for each performance test to the Department 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

Maricopa County Air Quality Department Page 7 of 15

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

[County Rule 270 §301.1] [SIP Rule 27 §B]

h. Notice of Testing: The Permittee shall notify the Department in writing at least two weeks in advance of the actual date and time of each performance test unless otherwise specified in the applicable standard or in this permit so that the Department may have a representative attend.

[County Rule 270 §404]

i. 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.

[County Rule 270 §405] [SIP Rule 42]

j. 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 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.

[County Rule 270 §406]

k. Test Report Submittal: The Permittee shall complete and submit a separate test report for each performance test to the Department within 60 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.

Reports shall be sent to: Maricopa County Air Quality Department, Attn: Permit Division Manager, 1001 Central Ave., Suite 400, Phoenix, AZ 85004-1944.

[County Rule 270 §301.1] [SIP Rule 27 §B]

l. 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.

m. Correspondence: All test extension requests, test protocols, test date notifications, and test reports required by this permit shall be submitted to the Department and addressed to the attention of the Performance Test Evaluation Supervisor.

[County Rule 270 §301.1] [SIP Rule 27 §B]

n. 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.

[County Rule 200 §309] [County Rule 270 §402.5]

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LFG CONTROLS – CARBON ADSORPTION at CELL A-1

13. Controls:

CARBON ADSORPTION SYSTEM (CAS) at CELL A-1:

Granulated Activated Carbon (GAC) // 1000 lb canisters (3x) Potassium Permanganate (KMnO4) // 2000 lb canisters (2x)

a. LFG generated at Cell A-1 shall be captured and routed at all times to the CAS for the control of LFG non-methane organic compound (NMOC) emissions and hazardous air pollutants (HAPs).

b. Proper operation shall be construed as the CAS having at least a 98% destruction efficiency by weight for NMOCs or reduce the outlet NMOC concentration to less than 20 parts per million by volume, dry basis as hexane at 3 percent oxygen as demonstrated by testing and analysis as conducted per Permit Condition 14.

c. Breakthrough:

i. The Permittee shall replace canisters before breakthrough is reached as well as anytime breakthrough is discovered.

ii. For the purpose of this Permit, breakthrough shall be defined at less than a 98% removal efficiency, or, an NMOC outlet concentration of greater than 20 ppmv for a single GAC canister/tank.

iii. Breakthrough shall be determined by sampling and analysis (see Permit Condition 14) and calculations using manufacturer specifications and the site specific data derived from testing. If testing indicates breakthrough has occurred and this result is other than expected from otherwise specified GAC life expectancy, the former testing result shall supersede the latter and shall replace calculated or specified parameters for managing the CAS.

iv. When breakthrough is determined to occur for the first stage canister/tank of the series, the first stage canister/tank shall be taken offline and the second stage canister/tank shall assume the first stage position. Likewise, if there are more than two canisters/tanks, each canister/tank shall be moved upstream one position and the new canister/tank with fresh GAC shall always assume the final stage position.

v. The Permittee shall replace canisters before breakthrough for the first stage canister/tank is reached as well as anytime breakthrough is discovered. The GAC replacement schedule may only be extended if a new breakthrough time period is first established through testing. This replacement schedule does not relieve the Permittee from the requirements of assuring a NMOC removal efficiency of at least 98%, as measured in accordance with Permit Condition 14, or a NMOC outlet concentration of less than or equal to 20 ppmv measured using an organic vapor meter (such as a photoionization detector, PID) calibrated with hexane. If another calibration gas is used, the measurement shall be correlated and expressed as hexane.

d. The CAS shall have a maximum LFG inlet stream of 200 scfm.

[Rule 220 §302.2, and §302.16]

e. The Permittee shall store spent carbon removed from the system in closed containers prior to removal from the site.

f. The Permittee shall not perform regeneration of spent carbon without first applying for a modification.

g. The CAS and associated monitoring equipment shall be operated in accordance with an operation and maintenance plan, as required by Permit Condition 8.

[Rule 320 §302] [SIP Rule 32.C]

14. Vapor Sampling Requirements (Grab Sampling and Method 25C):

** Note: CAS testing for this site was last performed in February 2016 and is required to be performed again as identified in Permit Condition 12.b, on the same schedule as the flare. **

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a. Testing Requirements: The Permittee shall test the CAS to demonstrate compliance with these Permit Conditions as follows:

i. The Permittee shall take representative grab samples of the gases entering and exiting the CAS every 5 years and as specified in Permit Condition 12.b.

ii. The Permittee shall determine from the representative grab samples the concentration of NMOC at the inlet and outlet of the CAS and the percent NMOC removal efficiency by laboratory testing using EPA 25C.

iii. The Permittee shall determine the volumetric flow rate of the gas streams into the control device using the flow rate monitor required by Permit Condition 9 calibrated in accordance with the manufacturer’s specifications. The results shall be used to perform the necessary calculations and demonstrate compliance with these Permit Conditions.

iv. If a dilution or flow control device is present in the system, the Permittee shall measure and record its position.

[Rule 200 §310.1, Rule 270 §401] [SIP Rule 25; SIP Rule 27]

b. Operating Conditions: Sampling and flow rate monitoring 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. 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 testing.

[Rule 270 §403] [Locally Enforceable Only]

c. Records: The following information shall be recorded for each grab sample:

i. Date of sampling, type of air pollution control in use, and the name of the company performing the laboratory analyses;

ii. Actual volumetric flow rate of the gases exiting the CAS; and

iii. Process temperature of the CAS (°F).

[Rule 220 §302.7] [Locally Enforceable Only]

d. Notice of Sampling: The Permittee shall notify the Control Officer in writing at least two weeks in advance of the actual date and time of all testing and analysis required under this Permit Condition unless otherwise specified in the applicable standard or in this Permit so that the Control Officer may have a representative attend.

[Rule 270 §404] [Locally Enforceable Only]

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

[Rule 270 §405] [SIP Rule 42]

f. Test Report Submittal: The Permittee shall complete and submit a separate test report for each test to the Control Officer within 30 days after the completion of testing. The report shall include, at a minimum, the information specified in Subsection [c] of this Permit Condition along with the following for each grab sample:

i. The concentration of NMOC at the inlet and outlet of the CAS (ppmv);

ii. The emission rate of NMOC exiting the CAS (lb/hr);

iii. The NMOC removal efficiency for the CAS.

[Rule 270 §401] [SIP Rule 27.A]

g. Compliance with allowable emission limits and standards shall be determined by the tests specified in this Permit Condition. 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

Maricopa County Air Quality Department Page 10 of 15 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.

[Rule 270 §407] [Locally Enforceable Only]

h. Correspondence: All test notices, extension requests, test protocols, test date notifications, and test reports required by this Permit shall be submitted to the Control Officer and addressed to the attention of the Permit Division Manager.

[Rule 270 §401] [SIP Rule 27 §A]

i. 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.

[Rule 200 §309; Rule 270 §402.5] [Locally Enforceable Only]

RULE 310: FUGITIVE DUST from DUST-GENERATING OPERATIONS

15. Applicability:

a. The provisions of this Permit Section apply to all dust-generating operations except for those dust-generating operations listed in the Condition 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 or there is no approved Dust Control Plan, 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 Dust Control Plan, shall constitute a violation.

[SIP Rule 310 §§102, 301]

16. 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]

17. 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.

Maricopa County Air Quality Department Page 11 of 15

[SIP Rule 100 §200.27]

18. Dust Control Plan Requirements:

a. The owner and/or operator of a dust-generating operation shall submit to the Control Officer a Dust Control Plan with any permit applications that involve dust-generating operations with a disturbed surface area that equals or exceeds 0.10 acre (4,356 square feet) before commencing any routine dust-generating operation. The Dust Control Plan shall be kept available onsite at all times.

b. The Permittee shall comply with the requirements of the Dust Control Plan and the provisions of MCAQD Rule 310 Sections 301 – 310 at all times.

[SIP Rule 310 §§ 301-310, 409]

19. 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]

20. 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 Dust Control Plan, an owner and/or operator shall:

i. Ensure that all control measures and requirements of the Dust Control Plan 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 conditions.

iii. Compile records consistent with the recordkeeping requirements of these Permit Conditions and document the control measure and other Dust Control Plan 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]

21. 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/ft². However, if silt loading is equal to or greater than 0.33 oz/ft², 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 construction or at a work site that is temporarily or permanently inactive) 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/ft². However, if silt loading is equal to or greater than 0.33 oz/ft², then the owner and/or operator shall not allow the silt content to exceed 6%.

Maricopa County Air Quality Department Page 12 of 15

ii. The owner and/or operator of any unpaved haul/access road (including at a work site that is under construction or a work site that is temporarily or permanently inactive) shall, as an alternative to meeting the stabilization requirements for an unpaved haul/access road in Subsection [21.b.i] of this Condition, limit vehicle trips to no more than 20 per day per road and limit vehicle speeds to no more than 15 miles per hour. If complying with this subsection of this Permit, the owner and/or operator must include, in a Dust Control Plan, the maximum number of vehicle trips on the unpaved haul/access roads each day (including number of employee vehicles, earthmoving equipment, haul trucks, and water trucks) and a description of how vehicle speeds will be restricted to no more than 15 miles per hour.

[SIP Rule 310 §304.2]

c. Disturbed Surface Area: The owner and/or operator of any disturbed surface area on which no activity is occurring (including at a work site that is under construction or a work site that is temporarily or permanently inactive) shall meet at least one of the standards described below, as applicable. Should such a disturbed surface area contain more than one type of stabilization characteristic, such as soil, vegetation, or other characteristic, which is visibly distinguishable, then the owner and/or operator shall test each representative surface separately for stability, in an area that represents a random portion of the overall disturbed conditions of the site, in accordance with the appropriate test methods described in Section 501.2(c) of Rule 310 and in Appendix C (Fugitive Dust Test Methods) of MCAQD rules. The owner and/or operator of such disturbed surface area on which no activity is occurring shall be considered in violation of Rule 310 if the area is not maintained in a manner that meets at least one of the standards listed below, as applicable. An area is considered to be a disturbed surface area until the activity that caused the disturbance has been completed and the disturbed surface area meets the standards described in this subsection.

i. Maintain a soil crust;

ii. Maintain a threshold friction velocity (TFV) for disturbed surface areas corrected for non-erodible elements of 100 cm/second or higher;

iii. Maintain a flat vegetative cover (i.e., attached (rooted) vegetation or unattached vegetative debris lying on the surface with a predominant horizontal orientation that is not subject to movement by wind) that is equal to at least 50%;

iv. Maintain a standing vegetative cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is equal to or greater than 30%;

v. Maintain a standing vegetative cover (i.e., vegetation that is attached (rooted) with a predominant vertical orientation) that is equal to or greater than 10% and where the threshold friction velocity is equal to or greater than 43 cm/second when corrected for non-erodible elements;

vi. Maintain a percent cover that is equal to or greater than 10% for non-erodible elements; or

vii. Comply with a standard of an alternative test method, upon obtaining the written approval from the Control Officer and the Administrator.

[SIP Rule 310 §304.3]

22. Soil Moisture:

If water is the chosen control measure in an approved Dust Control Plan, the owner and/or operator of a dust-generating operation shall operate a water application system on-site (e.g., water truck, water hose) while conducting any earthmoving operations on disturbed surface areas 1 acre or larger, unless a soil crust is maintained or the soil is sufficiently damp to prevent loose grains of soil from becoming dislodged.

[SIP Rule 310 §307]

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

a. At least once every three years, the following people shall successfully complete a Basic Dust Control Training Class conducted or approved by the Control Officer.

i. Water truck drivers.

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ii. Water-pull drivers.

iii. The site superintendent or other designated on-site representative of the permit holder.

b. Any certification issued to a person having successfully completed a Basic Dust Control Training Class conducted or approved by the Control Officer may be suspended or revoked for cause, including, but not limited to, inappropriate ethical activities or conduct associated with the dust control program.

[SIP Rule 310 §309.1]

24. Dust Control Plan Revisions

a. If the Control Officer determines that an approved Dust Control Plan has been followed, yet fugitive dust emissions from any dust-generating operation still exceed the standards of this Permit, the Control Officer shall issue a written notice to the owner and/or operator of the dust-generating operation explaining such determination. The owner and/or operator of a dust-generating operation shall make written revisions to the Dust Control Plan and shall submit such revised Dust Control Plan to the Control Officer within three working days of receipt of the Control Officer’s written notice, unless such time period is extended by the Control Officer, upon request, for good cause. During the time that such owner and/or operator is preparing revisions to the approved Dust Control Plan, such owner and/or operator must still comply with all requirements of this Permit.

[SIP Rule 310 §403.1]

b. The Permittee shall request a Dust Control Plan revision with a submittal in the manner and form prescribed by the Control Officer if:

i. The acreage of a project changes;

ii. The permit holder changes;

iii. The name(s), address(es), or phone numbers of person(s) responsible for the submittal and implementation of the Dust Control Plan and responsible for the dust-generating operation change;

and

iv. If the activities related to the purposes for which the Dust Control permit was obtained change.

[SIP Rule 310 §403.2]

25. Recordkeeping:

The Permittee shall maintain the following records for the time period specified in Condition 26 and make them available to the Control Officer upon request:

a. The Permittee shall keep a written record of self-inspection on each day dust-generating operations are conducted. Self-inspection records shall include daily inspections for crusted or damp soil, trackout conditions and clean-up measures, daily water usage, and dust suppressant application. Such written record shall also include the following information:

i. Method, frequency, and intensity of application or implementation of the control measures;

ii. Method, frequency, and amount of water application to the site;

iii. Street sweeping frequency;

iv. Types of surface treatments applied to and maintenance of trackout control devices, gravel pads, fences, wind barriers, and tarps;

v. Types and results of test methods conducted;

vi. If contingency control measures are implemented, actual application or implementation of contingency control measures and why contingency control measures were implemented;

vii. List of subcontractors’ names and registration numbers updated when changes are made; and

viii. Names of employee(s) who successfully completed dust control training class(es), date of the class(es) that such employee(s) successfully completed, and name of the agency/representative who conducted such class(es).

Maricopa County Air Quality Department Page 14 of 15

[SIP Rule 310 §502.1]

b. Upon verbal or written request by the Control Officer, the log or the records and supporting documentation shall be provided as soon as possible but no later than 48 hours after the request, excluding weekends.