DAQ-2025-001781

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DAQC-319-25
Site ID 10725 (B1)

MEMORANDUM

TO: FILE – CLEAN HARBORS ARAGONITE, LLC

THROUGH: Harold Burge, Major Source Compliance Manager

FROM: Joe Rockwell, Environmental Scientist

DATE: March 24, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Tooele County
FRS UT0000004904500048

INSPECTION DATE: March 20, 2025

SOURCE LOCATION: 11600 North Aptus Road
Aragonite, Utah 84029

From Salt Lake take I-80 west to the Aragonite exit (exit 56) and go
south on Aptus Road. The facility is at the end of the road.

MAILING ADDRESS: Clean Harbors Aragonite, LLC
P.O. Box 1339
Grantsville, Utah 84023-1339

SOURCE CONTACTS: Cody Parks – Plant Manager
Office: 435-884-8242

Kenneth Banks – Senior Compliance Manager
Office: 435-884-8233
Mobile: [phone]
[e-mail]

Bryan Lunt – Facility Operations Manager
Office: 435-884-8309
Mobile: [phone]
[e-mail]

Jim Saddler – Incineration Manager
Office: 435-241-2795

OPERATING STATUS: Operating

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PROCESS DESCRIPTION:

Clean Harbors Aragonite (CHA) is a commercial hazardous waste treatment, storage, and disposal facility
(TSDF). Hazardous waste is received from various sources including refineries, chemical manufacturing
plants, and coke by-product recovery plants. The off-site material management unit at the source includes
sixteen liquid waste storage and blending tanks, two sludge tanks, four bulk solids tanks, and several
container management buildings. Waste from the off-site material management unit is treated in an
incinerator which includes primary and secondary chambers. The incinerator control system includes a
spray dryer, carbon injection, baghouse, saturator, and wet scrubber. The source is major for HAPs, SO2,
and NOx. Hazardous waste is received by truck (tankers and gondolas) and occasionally by rail car.
Hazardous waste is only received by rail car at the Clive facility which is then trucked to the Aragonite
facility. The containers have a lab sample drawn and analyzed to ensure the material meets the manifest
limits and is considered to be acceptable material. If the material has to be held, the trailer is parked in a
holding area, which allows holding for up to 10 days. However, most of the material is dumped directly
after delivery. Solid waste is dumped directly to the bulk solid tanks which are in an enclosed building.
The waste is then mixed using a backhoe and clam shell before being placed in a shredder. This material
is then directed for incineration. The fumes from the solid’s buildings are vented to the incinerator or to a
carbon absorption system if the incinerator is down. The liquid waste is pumped into a sludge tank and
storage area. This liquid is then further characterized, and then pumped to one of twelve 30,000-gallon
storage tanks. These tanks are pumped to one of four tanks for blending, and then transferred to the kiln
or afterburner area for destruction. The fumes from the liquid waste tanks and sludge tanks are ducted to
the incinerator or to a set of carbon adsorption canisters if the incinerator is off-line. The solids are placed
in 55-gallon drums and then placed on a conveyor which goes to an elevator and then to a shelf where
they are pushed into the kiln by a ram. The liquid waste is pumped directly to the back wall of the main
kiln and also, to the back wall of the after-burner section to provide additional heat. There is a storage
tank with used clean fuel which can be pumped to the after burner to increase the BTU (if waste material
BTU is too low) to ensure complete incineration. The solids (residue) from the kiln drop to a collection
bin for destruction elsewhere. The fumes from the kiln go to a counter-current spray dryer for cooling,
and then to an 8 compartment, pulsejet baghouse for further particulate removal. After the baghouse, the
fumes go through a wet saturator, wet scrubber, fan housing, and then to the atmosphere through the
stack. The particulate from the baghouse is augured to an enclosed collection bin and returned to the kiln.
All of the kiln parameters and control functions are controlled from a central computer system in the
kiln’s control room.

APPLICABLE REGULATIONS: Title V Operating Permit (TVOP) #4500048004, dated
November 23, 2021.

NSPS (Part 60), A: General Provisions
NSPS (Part 60), Kb: Standards of Performance for Volatile
Organic Liquid Storage Vessels for which Construction,
Reconstruction, or Modification Commenced after July 23, 1984
NSPS (Part 60), JJJJ: Standards of Performance for Stationary
Spark Ignition Internal Combustion Engines

NESHAP (Part 61), A: General Provisions
NESHAP (Part 61), C: Beryllium
NESHAP (Part 61), E: Mercury
NESHAP (Part 61), FF: Benzene Waste Operations

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NESHAP (Part 63), A: General Provisions
NESHAP (Part 63), G: Organic Hazardous Air Pollutants Form
the Synthetic Organic Chemical Manufacturing Industry for
Process Vents, Storage Vessels, Transfer Operations, and
Wastewater
NESHAP (Part 63), DD: Off-Site Waste and Recovery
Operations
NESHAP (Part 63), GGG: Pharmaceuticals Production
NESHAP (Part 63), EEE: Hazardous Air Pollutant from
Hazardous Waste Combustors
NESHAP (Part 63), U: Group I Polymers and Resins
NESHAP (Part 63), XX: Ethylene Manufacturing Process Units:
Heat Exchange Systems and Waste Operations
NESHAP (Part 63), YY: Source Categories: Generic Maximum
Achievable Control Technology Standards
NESHAP (Part 63), JJJ: Paper and Other Web Coating
NESHAP (Part 63), MMM: Surface Coating of Miscellaneous
Metal Parts and Products
NESHAP (Part 63), PPP: Emissions of Polyether Polyols
Production
NESHAP (Part 63), GGGGG: Site Remediation
NESHAP (Part 63), UUUU: Cellulose Products Manufacturing
NESHAP (Part 63), ZZZZ: Stationary Reciprocating Internal
Combustion Engines

SOURCE EVALUATION:
SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of 1990
(CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

Status: This is a statement of fact and not an inspection item.

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in compliance
with this permit. (See also Provision I.E, Application Shield)

Status: This is a statement of fact and not an inspection item.

I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any of
the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

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I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that the
Director may request in writing to determine whether cause exists for modifying, revoking
and reissuing, or terminating this permit or to determine compliance with this permit. Upon
request, the permittee shall also furnish to the Director copies of records required to be kept
by this permit or, for information claimed to be confidential, the permittee may furnish such
records directly to the EPA along with a claim of confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause.
The filing of a request by the permittee for a permit modification, revocation and
reissuance, or termination, or of a notification of planned changes or anticipated
noncompliance shall not stay any permit condition, except as provided under R307-415-
7f(1) for minor permit modifications. (R307-415-6a(6)(c))

Status: This is a statement of fact and not an inspection item.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late application.
(R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: The permit expires November 23, 2026. Application for renewal is due May 23, 2026.

I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and
conditions of this permit shall remain in force until permit renewal or denial. This
protection shall cease to apply if, subsequent to the completeness determination required
pursuant to R307-415-7a(3), and as required by R307-415-5a(2), the applicant fails to
submit by the deadline specified in writing by the Director any additional information
identified as being needed to process the application. (R307-415-7b(2))

Status: Application for renewal is due May 23, 2026.

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I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

Status: This is a statement of fact and not an inspection item.

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with R307-415-9.
(R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the source
receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance – According to CHA the annual emission fee’s invoice payment was made on August
19, 2024. Before the due date of October 3, 2023. See the SLEIS database.

I.H No Property Rights.

This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

Status: This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives, marketable
permits, emissions trading and other similar programs or processes for changes that are
provided for in this permit. (R307-415-6a(8))

Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the permittee
shall allow the Director or an authorized representative to perform any of the following:

I.J.1.a Enter upon the permittee's premises where the source is located or emissions related
activity is conducted, or where records are kept under the conditions of this permit.
(R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept under the
conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and air
pollution control equipment), practice, or operation regulated or required under this
permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose of
assuring compliance with this permit or applicable requirements. (R307-415-6c(2)(d))
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I.J.2 Any claims of confidentiality made on the information obtained during an inspection shall be
made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In compliance – Required records were made available and no claims of confidentially were
made at time of the inspection.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this permit
shall contain certification as to its truth, accuracy, and completeness, by a responsible official
as defined in R307-415-3. This certification shall state that, based on information and belief
formed after reasonable inquiry, the statements and information in the document are true,
accurate, and complete. (R307-415-5d)

Status: In compliance – Reports and certifications submitted, by CHA, appeared to have certification
statements and were signed by the responsible officials.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later than the
date shown under "Enforceable Dates and Timelines" at the front of this permit, and that date
each year following until this permit expires. The certification shall include all the following
(permittee may cross-reference this permit or previous reports): (R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this permit. If
necessary, the permittee also shall identify any other material information that must be
included in the certification to comply with section 113(c)(2) of the Act, which
prohibits knowingly making a false certification or omitting material information;

I.L.1.c The status of compliance with the terms and conditions of the permit for the period
covered by the certification, including whether compliance during the period was
continuous or intermittent. The certification shall be based on the method or means
designated in Provision I.L.1.b. The certification shall identify each deviation and take
it into account in the compliance certification. The certification shall also identify as
possible exceptions to compliance any periods during which compliance is required
and in which an excursion or exceedance as defined under 40 CFR Part 64 occurred;
and

I.L.1.d Such other facts as the Director may require to determine the compliance status.

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I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director: (R307-415-
6c(5)(d))

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

Status: In compliance – The most recent annual compliance certification, dated September 20, 2024,
was emailed to the DAQ on September 20, 2024. The hardcopy of the report was received on
September 24, 2024, and deemed acceptable. The report is considered to have been received by
the due date, September 22, 2024. See Compliance Assistance below.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any applicable
requirements as of the date of this permit, provided that:

I.M.1.a Such applicable requirements are included and are specifically identified in this
permit, or (R307-415-6f(1)(a))

I.M.1.b Those requirements not applicable to the source are specifically identified and listed in
this permit. (R307-415-6f(1)(b))

I.M.2 Nothing in this permit shall alter or affect any of the following:

I.M.2.a The emergency provisions of Utah Code Ann. Section 19-1-202 and Section 19-2-112,
and the provisions of the CAA Section 303. (R307-415-6f(3)(a))

I.M.2.b The liability of the owner or operator of the source for any violation of applicable
requirements under Utah Code Ann. Section 19-2-107(2)(a)(xiii) and Section 19-2-110
prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d The ability of the Director to obtain information from the source under Utah Code
Ann. Section 19-2-120, and the ability of the EPA to obtain information from the
source under the CAA Section 114. (R307-415-6f(3)(d))

Status: N/A – See section III of this permit.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
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the extent caused by improperly designed equipment, lack of preventive maintenance, careless
or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two working
days of the time when emission limitations were exceeded due to the emergency. This
notice must contain a description of the emergency, any steps taken to mitigate
emissions, and corrective actions taken. This notice fulfills the requirement of
Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4 This emergency provision is in addition to any emergency or upset provision contained in any
other section of this permit. (R307-415-6g(5))

Status:

No emergency events were reported since the last inspection, which was conducted on April 5,
2024.

I.O Operational Flexibility.

Operational flexibility is governed by R307-415-7d(1).

I.P Off-permit Changes.

Off-permit changes are governed by R307-415-7d(2).

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

I.R Permit Modifications.

Permit modifications are governed by R307-415-7f.

Status: These are statements of fact and not inspection items (I.O through I.R).

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I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be retained
by the permittee for a period of at least five years from the date of the monitoring
sample, measurement, report, or application. Support information includes all
calibration and maintenance records, all original strip-charts or appropriate recordings
for continuous monitoring instrumentation, and copies of all reports required by this
permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the source
shall record the following information, where applicable: (R307-415-6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

I.S.1.b.3 The company or entity that performed the analyses.

I.S.1.b.4 The analytical techniques or methods used.

I.S.1.b.5 The results of such analyses.

I.S.1.b.6 The operating conditions as existing at the time of sampling or measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

Status: In compliance – Required records were provided, for review, at time of the inspection.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a responsible
official in accordance with Provision I.K of this permit. (R307-415-6a(3)(c)(i)

I.S.2.c The Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset conditions as defined in this permit, the probable
cause of such deviations, and any corrective actions or preventative measures taken.
Prompt, as used in this condition, shall be defined as written notification within the
number of days shown under "Enforceable Dates and Timelines" at the front of this
permit. Deviations from permit requirements due to breakdowns shall be reported in
accordance with the provisions of R307-107. (R307-415-6a(3)(c)(ii))

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I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions required by this permit to be submitted
to the EPA should be sent to one of the following addresses or to such other address
as may be required by the Director:

For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

For reports, notifications, or other correspondence related to permit modifications,
applications, etc.:

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch (mail code 8ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone].

Status: In compliance – Six-month monitoring reports for report periods May 2023 – October 2023,
November 2023 – April 2024, and May 2024 – October 2024, have been received and deemed
acceptable. No deviations were reported.

CHA will only send two, instead of three monitoring reports in the future, that will cover the
report period for the annual compliance certifications. See Compliance Assistance and attached
Request to Modify Timeframe for Semi-Annual Monitoring Report correspondence.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if the
effective date of the requirement is later than the date on which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant to
R307-415-7c(3), application shield. (R307-415-7g(1)(a))

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I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))
I.T.1.c EPA or the Director determines that this permit must be revised or revoked to assure
compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal date of
this permit and are in conflict with existing permit conditions. (R307-415-7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to a
Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit. (R307-415-
7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: This is a statement of fact and not an inspection item.

I.U Inventory Requirements.

An emission inventory shall be submitted in accordance with the procedures of R307-150,
Emission Inventories. (R307-150)

Status: In compliance – The 2023 triannual emission inventory was received on April 10, 2024. The 2026
emission inventory is due by April 15, 2027. See the SLEIS database and Emission Inventory.

I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both provisions
shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: This is a statement of fact and not an inspection item.

SECTION II: SPECIAL PROVISIONS

II.A Emission Unit(s) Permitted to Discharge Air Contaminants.
(R307-415-4(3)(a) and R307-415-4(4))

II.A.1 Permitted Source
Source-wide

II.A.2 Incineration System (INC)
One liquid, solid and sludge hazardous waste incinerator with a rotary kiln and afterburner.
Emissions are controlled by a spray dryer, carbon injection, baghouse, saturator, wet scrubber.

II.A.3 Offsite Material Management Unit (GRP)
Includes containers, transfer systems, tanks, and equipment components used to manage off-site
material. Also includes repack room with Procedure-T enclosure and carbon adsorption system,
medical water repacking system, and a shred tower.
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II.A.4 Off-Site Material Containers (CNT)
Container means a portable unit used to hold off-site materials. Examples of containers include but
are not limited to drums, dumpsters, roll-off boxes, bulk cargo containers commonly known as
"portable tanks" or totes, and cargo tank trucks.

II.A.5 Off-Site Material Transfer Systems (TRNS)
The source has various off-site material transfer systems used to convey liquids, sludges, and solids
from one point to another point. These systems all consist of continuous hard piping.

II.A.6 Off-Site Material Tanks (TNKS)
This group includes sixteen liquid tanks (TNK1), two sludge tanks (TNK2), and three solid off-site
material storage tanks (TNK3).

II.A.7 Liquid Off-Site Material Tank Farm (TNK1)
Sixteen 30,000 gallon tanks for liquid off-site material storage and blending. Each tank is equipped
with a fixed roof. The tanks vent to either the incinerator afterburner or to a carbon canister system.

II.A.8 Sludge Off-Site Material Tanks (TNK2)
One 5,000-gallon sludge receiving tank and one 38,000 gallon fixed-roof sludge storage tank. The
storage tanks emit to the incinerator afterburner or carbon bed.

II.A.9 Solid Off-Site Material Tanks (TNK3)
Three tanks with a capacity to store 200, 500, and 500 cubic yards of solid off-site material. These
tanks are located in an enclosure which is vented to the afterburner or carbon bed.

II.A.10 Diesel Tanks
One 4,000 gallon submerged diesel storage tank and two 250 gallon diesel storage tanks. No unit-
specific applicable requirements.

II.A.11 Fuel Oil Tank
101,000 gallon fuel oil storage tank. No unit-specific applicable requirements.

II.A.12 Gasoline Tank
One 4000 gallon gasoline storage tank, equipped with a submerged fill pipe and Stage I vapor recovery
equipment. No unit-specific applicable requirements.

II.A.13 Soda Ash Bin
One soda ash bin with a baghouse.

II.A.14 Carbon Silo
One carbon Silo with a baghouse

II.A.15 Cooling Towers
Two cooling towers. No unit-specific applicable requirements.

II.A.16 Emergency Generators
One diesel fired generator rated at 2,149 hp (manufactured in 1989), and one propane fired generator
rated at 175 kW (NSPS JJJJ).

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II.A.17 Diesel Engine for Water Pump
One diesel fired water pump rated at 276 hp.

Status: In compliance – No unapproved equipment was noted at time of the inspection.

II.B

Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted
facility as indicated:

II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

Unless otherwise specified, at all times, including periods of startup, shutdown, and malfunction,
the permittee shall, to the extent practicable, maintain and operate any permitted plant equipment,
including associated air pollution control equipment, in a manner consistent with good air pollution
control practice for minimizing emissions. Determination of whether acceptable operating and
maintenance procedures are being used will be based on information available to the Director
which may include, but is not limited to, monitoring results, opacity observations, review of
operating and maintenance procedures, and inspection of the source.

[Authority granted under R307-401-8(2); condition originated in DAQE-AN107250026A-16].

II.B.1.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.a.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of
this permit.

Status: In compliance – The facility appeared to be properly maintained and operated at time of the
inspection. The Facility Assets Management (FAM) database is used to track maintenance. The
facility is shut down semi-annually during the spring and fall to conduct major maintenance. The
last facility shutdown was from March 3, 2025 – March 15, 2025.

II.B.1.b Condition:

A Risk Management Plan (RMP) developed in accordance with 40 CFR Part 68 shall be submitted to
the United States Environmental Protection Agency not later than the applicable date in 40 CFR 68.

[Authority granted under 40 CFR 68; condition originated in 40 CFR 68]

14
II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.b.2 Recordkeeping:

A copy of the Risk Management Plan shall be available to the Director upon request along
with a copy of the transmittal letter to EPA.

II.B.1.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of
this permit.

Status: In compliance – The Risk Management Plan (RMP) (Level 1) was last updated and submitted to
EPA on November 11, 2021. The plan is reviewed and submitted every five years or sooner
depending on triggers.

II.B.1.c Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions
Reduction.

[Authority granted under 40 CFR 82.150(b); condition originated in 40 CFR 82]

II.B.1.c.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.c.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.c.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – All refrigerant services are performed by the certified third-party contractor
Midgley Huber Inc. (MHI).

II.B.1.d Condition:

The permittee shall comply with the applicable requirements for production and consumption controls
for ozone-depleting substances pursuant to 40 CFR 82, Subpart A - Production and Consumption
Controls.

[Authority granted under 40 CFR 82 Subpart A; condition originated in 40 CFR 82]

15
II.B.1.d.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart A.

II.B.1.d.2 Recordkeeping:

All records required in 40 CFR 82, Subpart A shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.d.3 Reporting:

All reports required in 40 CFR 82, Subpart A shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – The annual ozone depleting substance (ODS) report was submitted to the EPA,
on January 23, 2025, for report year (RY) 2024.

II.B.1.e Condition:

(1) Prior to accepting Group 1wastewaters (or residuals removed from Group 1 wastewaters) from
generators subject to the treatment requirements of 40 CFR 63 Subpart G, the permittee shall submit
to the EPA a written certification. The certification shall state that the permittee will manage and treat
such waste in accordance with the requirements of 40 CFR 63.133 through 63.147. Alternatively, the
certification may state that the permittee will manage and treat the wastes in accordance with the
requirements of 40 CFR 63.102(b) of subpart F, or 40 CFR 63-subpart D, if alternative emission
limitations have been granted the transferor in accordance with those provisions. The permittee may
revoke the written certification by sending a written statement to the EPA and the sources, giving at
least 90 days’ notice that the permittee is rescinding acceptance of responsibility for compliance with
the regulatory provisions listed in this paragraph.

(2) By providing this written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions listed in paragraph (1) of this condition with respect to any
shipment of wastewater or residual covered by the written certification.

(3) Written certifications and revocation statements, to the EPA from the permittee, shall be signed
by the responsible official, provide the name and address of the permittee, and be sent to the
appropriate EPA Regional Office at the addresses listed in 40 CFR 63.13. Such written certifications
are not transferable by the permittee.

[Authority granted under 40 CFR 63.132(g); condition originated in 40 CFR 63 Subpart G]

II.B.1.e.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 63, Subpart G.

II.B.1.e.2 Recordkeeping:

All records required in 40 CFR 63, Subpart G shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

16
II.B.1.e.3 Reporting:

All reports required in 40 CFR 63, Subpart G shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – The Initial Certification was submitted to the EPA, for managing wastes
subject to 40 CFR 63 Subpart G on June 23, 1999. The Certification dated February 15, 2023,
was resubmitted. Compliance regarding this condition is covered under the more stringent 40
CFR 63 Subpart DD and 40 CFR 61 Subpart V. Semi-annual notices are submitted according
to the subparts.

II.B.1.f Condition:

Sulfur content of any fuel oil or used oil combusted shall be no greater than 0.5 % by weight.

[Authority granted under R307- 401-8; condition originated in DAQE-AN107250026A-16]

II.B.1.f.1 Monitoring:

For each delivery of oil, the permittee shall either:

(1) Determine the fuel sulfur content expressed as wt% in accordance with the methods
of the American Society for Testing Materials (ASTM);

(2) Inspect the fuel sulfur content expressed as wt% determined by the vendor using
methods of the ASTM; or

(3) Inspect documentation provided by the vendor that indirectly demonstrates
compliance with this provision.

II.B.1.f.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this
permit.

II.B.1.f.3 Reporting:

There are no reporting requirements for this provision except those specified in Section
I of this.

Status: In compliance – The facility now receives two different types of fuels:

Fuel Type Vender Delivery Analysis
Used Oil Thermal Fluids Rail – March 20, 2025 Analysis Provided
#2 Diesel Hails Oil Company Truck – March 13, 2025 Invoice Indicates ULSD
Product Fuel Texmark Rail – Last delivered on
July 3, 2024. No longer
delivered to the facility.
CHA Conducts Analysis

17
II.B.1.g Condition:

(1) Prior to accepting Group 1wastewaters (or residuals removed from Group 1 wastewaters) from
generators subject to the treatment requirements of 40 CFR 63 Subpart GGG, the permittee shall
submit to the EPA a written certification. The certification shall state that the permittee will manage
and treat such waste in accordance with the requirements of either:

(i) Paragraphs (b) through (i) of 40 CFR 63.1256; or

(ii) Subpart D of 40 CFR 63 if alternative emission limitations have been granted the
transferor in accordance with those provisions; or

(iii) 40 CFR 63.6(g); or

(iv) If the affected wastewater streams or residuals removed from affected wastewater
streams received by the permittee contain less than 50 ppmw of partially soluble HAP,
then the permittee must, at a minimum, manage and treat the affected wastewater streams
and residuals in accordance with one of the following:

(A) Comply with paragraph (g)(10) of 40 CFR 63.1256 and cover the waste
management units up to the activated sludge unit; or

(B) Comply with paragraphs (g)(11)(i), (ii), and (h) of 40 CFR 63.1256 and cover
the waste management units up to the activated sludge unit; or

(C) Comply with paragraph (g)(10) of 40 CFR 63.1256 provided that the permittee
of demonstrates that less than 5 percent of the total soluble HAP is emitted from
waste management units up to the activated sludge unit; or

(D) than 5 percent of the total soluble HAP is emitted from waste management
units up to the activated sludge unit.

(2) By providing this written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions listed in paragraph (1) of this condition with respect
to any shipment of wastewater or residual covered by the written certification.

(3).The permittee may revoke the written certification by sending a written statement to the EPA
and to the generators, giving at least 90 days’ notice that the permittee is rescinding acceptance
of responsibility for compliance with the regulatory provisions listed in this condition.

(4).Written certifications and revocation statements, to the EPA from the permittee shall be
signed by the responsible official, provide the name and address of the permittee, and be sent to
the appropriate EPA Regional Office at the addresses listed in 40 CFR 63.13. Such written
certifications are not transferable by the permittee.

[Authority granted under 40 CFR 63.1256(a)(5); condition originated in 40 CFR 63 Subpart
GGG]

II.B.1.g.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of
this permit, its compliance status with the requirements of 40 CFR 63, Subpart GGG.

18
II.B.1.g.2 Recordkeeping:

All records required in 40 CFR 63, Subpart GGG shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.g.3 Reporting:

All reports required in 40 CFR 63, Subpart GGG shall be submitted as required. There
are no additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – The Initial Certification was submitted to the EPA, for managing wastes
subject to 40 CFR 63 Subpart GGG on November 3, 2011. The Certification was
resubmitted on November 5, 2020. Compliance regarding this condition is covered under
the more stringent 40 CFR 63 Subpart DD and 40 CFR 61 Subpart V. Semi-annual
notices are submitted according to the subparts.

II.B.1.h Condition:

(1) Prior to accepting Group 1wastewaters (or residuals removed from Group 1 wastewaters)
from generators subject to the treatment requirements of 40 CFR 63 Subpart U, the permittee
shall submit to the EPA a written certification. The certification shall state that the permittee will
manage and treat such waste in accordance with the requirements of 40 CFR 63.132 through
63.147 with differences identified in 40 CFR 63.501. The permittee may revoke the written
certification by sending a written statement to the EPA and to the generators, giving at least 90
days’ notice that the permittee is rescinding acceptance of responsibility for compliance with the
regulatory provisions listed in this paragraph.

(2) By providing this written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions listed in paragraph (1) of this condition with respect
to any shipment of wastewater or residual covered by the written certification.

(3) Written certifications and revocation statements to the EPA from the permittee, shall be
signed by the responsible official, provide the name and address of the permittee, and be sent to
the appropriate EPA Regional Office at the addresses listed in 40 CFR 63.13. Such written
certifications are not transferable by the permittee. [Authority granted under 40 CFR 63.501(a)
and 63.132(g); condition originated in 40 CFR 63 Subpart U and Subpart G].

II.B.1.h.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 63, Subpart U.

II.B.1.h.2 Recordkeeping:

All records required in 40 CFR 63, Subpart U shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

19
II.B.1.h.3 Reporting:

All reports required in 40 CFR 63, Subpart U shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – The Initial Certification was resubmitted to the EPA, for managing
wastes subject to 40 CFR 63 Subpart U on November 5, 2020. Compliance regarding this
condition is covered under the more stringent 40 CFR 63 Subpart DD and 40 CFR 61
Subpart V. Semi-annual notices are submitted according to the subparts.

II.B.1.i Condition:

(1) Prior to accepting Group 1wastewaters (or residuals removed from Group 1 wastewaters)
from generators subject to the treatment requirements of 40 CFR 63 Subpart XX, the permittee
shall submit to the EPA a written certification. The certification shall state that the permittee
will manage and treat such waste in accordance with the requirements of 40 CFR Subpart XX.
The permittee may revoke the written certification by sending a written statement to the EPA
and to the generators, giving at least 90 days’ notice that the permittee is rescinding acceptance
of responsibility for compliance with the regulatory provisions listed in this paragraph.

(2) By providing this written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions in 40 CFR 63 Subpart XX with respect to any
shipment of waste covered by the written certification.

(3) The permittee may revoke the written certification by sending a written statement to the
Director or generators. The notice of revocation must provide at least 90 days' notice that the
permittee is rescinding acceptance of responsibility of compliance with the regulator provisions
of 40 CFR 63 Subpart XX. Written certifications and revocation statements to the EPA from
the permittee shall be signed by the responsible official, provide the name and address of the
permittee, and be sent to the appropriate EPA Regional Office at the addresses listed in 40 CFR
63.13. Such written certifications are not transferable by the permittee.

[Authority granted under 40 CFR 63.1096; condition originated in 40 CFR 63 Subpart XX].

II.B.1.i.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of
this permit, its compliance status with the requirements of 40 CFR 63, Subpart XX.

II.B.1.i.2 Recordkeeping:

All records required in 40 CFR 63, Subpart XX shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.i.3 Reporting:

All reports required in 40 CFR 63, Subpart XX shall be submitted as required. There
are no additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – The Initial Certification was submitted to the USEPA, for managing
wastes subject to 40 CFR 63 Subpart XX on May 5, 2005. Compliance regarding this
condition is covered under the more stringent 40 CFR 63 Subpart DD and F. Semi-annual,
quarterly and annual notices are submitted according to the subparts.
20
II.B.1.j Condition:

(1) Prior to accepting Group 1wastewaters (or residuals removed from Group 1 wastewaters)
from generators subject to the treatment requirements of 40 CFR 63 Subpart YY, the permittee
shall submit to the EPA a written certification. The certification shall state that the permittee
will manage and treat such waste in accordance with the requirements of 40 CFR 63.132
through 63.147 with differences identified in 40 CFR 63.1106(a). The permittee may revoke
the written certification by sending a written statement to the EPA and to the generators, giving
at least 90 days’ notice that the permittee is rescinding acceptance of responsibility for
compliance with the regulatory provisions listed in this paragraph.

(2) By providing this written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions listed in paragraph (1) of this condition with respect
to any shipment of wastewater or residual covered by the written certification.

(3) Written certifications and revocation statements to the EPA from the permittee shall be
signed by the responsible official, provide the name and address of the permittee, and be sent to
the appropriate EPA Regional Office at the addresses listed in 40 CFR 63.13. Such written
certifications are not transferable by the permittee.

[Authority granted under 40 CFR 63.1106(a) and 63.132(g); condition originated in 40 CFR 63
Subpart YY and Subpart G].

II.B.1.j.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 63, Subpart YY.
II.B.1.j.2 Recordkeeping:

All records required in 40 CFR 63, Subpart YY shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.j.3 Reporting:

All reports required in 40 CFR 63, Subpart YY shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – The Initial Certification was resubmitted to the EPA, for managing
wastes subject to 40 CFR 63 Subpart YY on November 5, 2020. Compliance regarding
this condition is covered under the more stringent 40 CFR 63 Subpart DD. Semi-annual
notices are submitted according to the subpart.

II.B.1.k Condition:

(1) Prior to accepting Group 1wastewaters (or residuals removed from Group 1 wastewaters)
from generators subject to the treatment requirements of 40 CFR 63 Subpart JJJ, the permittee
shall submit to the EPA a written certification. The certification shall state that the permittee
will manage and treat such waste in accordance with the requirements of 40 CFR 63.132
through 63.147 with differences identified in 40 CFR 63.1330(a). The permittee may revoke
the written certification by sending a written statement to the EPA and to the generators, giving
at least 90 days’ notice that the permittee is rescinding acceptance of responsibility for
compliance with the regulatory provisions listed in this paragraph.

21
(2) By providing this written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions listed in paragraph (1) of this condition with respect
to any shipment of wastewater or residual covered by the written certification.

(3) Written certifications and revocation statements to the EPA from the permittee shall be
signed by the responsible official, provide the name and address of the permittee, and be sent to
the appropriate EPA Regional Office at the addresses listed in 40 CFR 63.13. Such written
certifications are not transferable by the permittee.

[Authority granted under 40 CFR 63.1330(b)(21)-(22) and 63.132(g); condition originated in
40 CFR 63 Subpart JJJ and Subpart G].

II.B.1.k.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 63, Subpart JJJ.

II.B.1.k.2 Recordkeeping:

All records required in 40 CFR 63, Subpart JJJ shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.k.3 Reporting:

All reports required in 40 CFR 63, Subpart JJJ shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – The Initial Certification was resubmitted to the EPA, for managing
wastes subject to 40 CFR 63 Subpart JJJ on November 5, 2020. Compliance regarding
this condition is covered under the more stringent 40 CFR 63 Subpart DD. Semi-annual
notices are submitted according to the subpart.

II.B.1.l Condition:

(1)Prior to accepting Group 1wastewaters (or residuals removed from Group 1 wastewaters)
from generators subject to the treatment requirements of 40 CFR 63 Subpart MMM, the
permittee shall submit to the EPA a written certification. The certification shall state that the
permittee will manage and treat such waste in accordance with the requirements of 40 CFR
63.132 through 63.147 with differences identified in 40 CFR 63.1362(d). The permittee may
revoke the written certification by sending a written statement to the EPA and to the generators,
giving at least 90 days’ notice that the permittee is rescinding acceptance of responsibility for
compliance with the regulatory provisions listed in this paragraph.

(2) By providing this written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions listed in paragraph (1) of this condition with respect
to any shipment of wastewater or residual covered by the written certification.

(3) Written certifications and revocation statements to the EPA from the permittee shall be
signed by the responsible official, provide the name and address of the permittee, and be sent to
the appropriate EPA Regional Office at the addresses listed in 40 CFR 63.13. Such written
certifications are not transferable by the permittee.

22
[Authority granted under 40 CFR 63.1362(d) and 63.132(g); condition originated in 40 CFR 63
Subpart MMM and Subpart G]

II.B.1.l.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 63, Subpart MMM.

II.B.1.l.2 Recordkeeping:

All records required in 40 CFR 63, Subpart MMM shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit [R307-415-6a]

II.B.1.l.3 Reporting:

All reports required in 40 CFR 63, Subpart MMM shall be submitted as required.
There are no additional reporting requirements except as outlined in Section I of this
permit.

Status: In compliance – The Initial Certification was submitted to the EPA, for managing wastes
subject to 40 CFR 63 Subpart MMM on January 12, 2007. Compliance regarding this
condition is covered under the more stringent 40 CFR 63 Subpart DD. Semi-annual
notices are submitted according to the subpart.

II.B.1.m Condition:

(1) Prior to accepting Group 1wastewaters (or residuals removed from Group 1 wastewaters)
from generators subject to the treatment requirements of 40 CFR 63 Subpart PPP, the permittee
shall submit to the EPA a written certification. The certification shall state that the permittee
will manage and treat such waste in accordance with the requirements of 40 CFR 63.132
through 63.147 with differences identified in 40 CFR 63.1433(a). The permittee may revoke
the written certification by sending a written statement to the EPA and to the generators, giving
at least 90 days’ notice that the permittee is rescinding acceptance of responsibility for
compliance with the regulatory provisions listed in this paragraph.

(2) By providing this written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions listed in paragraph (1) of this condition with respect
to any shipment of wastewater or residual covered by the written certification.

(3) Written certifications and revocation statements, to the EPA from the permittee shall be
signed by the responsible official, provide the name and address of the permittee, and be sent to
the appropriate EPA Regional Office at the addresses listed in 40 CFR 63.13. Such written
certifications are not transferable by the permittee.

[Authority granted under 40 CFR 63.1433(a) and 63.132(g); condition originated in 40 CFR 63
Subpart PPP and Subpart G]

II.B.1.m.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 63, Subpart PPP.

23
II.B.1.m.2 Recordkeeping:

All records required in 40 CFR 63, Subpart PPP shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.m.3 Reporting:

All reports required in 40 CFR 63, Subpart PPP shall be submitted as required. There
are no additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – The Initial Certification was resubmitted to the EPA, for managing wastes
subject to 40 CFR 63 Subpart PPP on November 5, 2020. Compliance regarding this
condition is covered under the more stringent 40 CFR 63 Subpart DD. Semi-annual
notices are submitted according to the subpart.

II.B.1.n Condition:

(1)Prior to accepting remediation materials subject to the treatment requirements of 40 CFR 63
Subpart GGGGG, the permittee shall either:

(a) Submit to the generator a written statement acknowledging that the exemption under
§63.680(b)(2)(iii) will be waived for all remediation material received and that material
will be managed as an off-site material at the facility according to all applicable
requirements 40 CFR 63 Subpart DD. This statement must be signed by the Title V
responsible official, provide the name and address of the Title V source, and a copy sent to
the appropriate EPA Regional Office at the addresses listed in 40 CFR 60.13. Or;

(b) Submit to the EPA a written certification that the permittee will manage remediation
material subject to the treatment requirements of 40 CFR 63 Subpart GGGGG according
to the requirements of 40 CFR 63.7885 through 63.7957. The permittee may revoke the
written certification by sending a written statement to the EPA and to the generator
providing at least 90 days’ notice that they rescind acceptance of responsibility for
compliance with the regulatory provisions listed in 40 CFR Part 63.7936.

(2) By providing the written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions listed in 40 CFR Part 63.7936(b)(3) with respect to
any shipment of remediation material covered by the written certification. Failure to abide by
any of those provisions with respect to such shipments may result in enforcement action by the
EPA against the certifying entity according to the enforcement provisions applicable to
violations of these provisions by owners or operators of sources.

(3) Written certifications and revocation statements to the EPA must be signed by the Title V
responsible official, provide the name and address of the Title V Source, and a copy sent to the
appropriate EPA Regional Office at the addresses listed in 40 CFR 63.13. Such written
certifications are not transferable. [Authority granted under 40 CFR 63.7936; condition
originated in 40 CFR 63 Subpart GGGGG]

II.B.1.n.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 63, Subpart GGGGG.

24
II.B.1.n.2 Recordkeeping:

All records required in 40 CFR 63, Subpart GGGGG shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.n.3 Reporting:

All reports required in 40 CFR 63, Subpart GGGGG shall be submitted as required.
There are no additional reporting requirements except as outlined in Section I of this
permit.

Status: In compliance – The Initial Certification was resubmitted to the EPA, for managing
wastes subject to 40 CFR 63 Subpart GGGGG on January 19, 2004. Compliance
regarding this condition is covered under the more stringent 40 CFR 63 Subpart DD.
Semi-annual notices are submitted according to the subpart.

II.B.1.o Condition:

(1) Prior to accepting Group 1wastewaters (or residuals removed from Group 1 wastewaters)
from generators subject to the treatment requirements of 40 CFR 63 Subpart UUUU, the
permittee shall submit to the EPA a written certification. The certification shall state that the
permittee will manage and treat such waste in accordance with the requirements of 40 CFR
63.132 through 63.140. The permittee may revoke the written certification by sending a written
statement to the EPA and to the generators, giving at least 90 days’ notice that the permittee is
rescinding acceptance of responsibility for compliance with the regulatory provisions listed in
this paragraph.

(2) By providing this written certification to the EPA, the permittee accepts responsibility for
compliance with the regulatory provisions listed in paragraph (1) of this condition with respect
to any shipment of wastewater or residual covered by the written certification.

(3) Written certifications and revocation statements to the EPA from the permittee shall be
signed by the responsible official, provide the name and address of the permittee, and be sent to
the appropriate EPA Regional Office at the addresses listed in 40 CFR 63.13. Such written
certifications are not transferable by the permittee.

[Authority granted under 40 CFR 63.5505(a) (Table 1, item 8) and 63.132(g); condition
originated in 40 CFR 63 Subpart UUUU and Subpart G]

II.B.1.o.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 63, Subpart UUUU.

II.B.1.o.2 Recordkeeping:

All records required in 40 CFR 63, Subpart UUUU shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

25
II.B.1.o.3 Reporting:

All reports required in 40 CFR 63, Subpart UUUU shall be submitted as required.
There are no additional reporting requirements except as outlined in Section I of this
permit.

Status: In compliance – The Initial Certification was resubmitted to the EPA, for managing
wastes subject to 40 CFR 63 Subpart UUUU on November 5, 2020. Compliance regarding
this condition is covered under the more stringent 40 CFR 63 Subpart DD. Semi-annual
notices are submitted according to the subpart.

II.B.2 Conditions on Incineration System (INC)

II.B.2.a Condition:

Emissions of Beryllium Compounds shall be no greater than 9.18 grams over any 24-hour period.

[Authority granted under R307-401-8; condition originated in DAQE-AN107250026A-16]

II.B.2.a.1 Monitoring:

Stack testing shall be conducted as follows:

(a) Frequency. Trial burn or performance testing shall be conducted when the testing is
required as outlined in 40 CFR Part 63, Subpart EEE.

(b )Notification. At least 30 days prior to conducting a stack test, the permittee shall notify the
Director of the date, time, and place of testing. A copy of the test protocol shall be provided
with the notification. The permittee and tester shall attend a pretest conference at least 30 days
prior to the test if determined necessary by the Director.

Within 90 days of test completion, CHA shall submit the trial burn or performance test results
to the Director.

(c) Methods. The pollutant emission rate in g/day shall be monitored in accordance with 40
CFR 61, Appendix B, Method 103 or 104, or in accordance with 40 CFR 60, Appendix A,
Method 29.

(d) Calculations. The permittee shall calculate the pollutant emission rate in g/day in
accordance with the selected method. Where emissions depend upon the relative frequency of
operation of different types of processes, operating hours, operating capacities, or other factors,
the calculation of maximum 24-hour-period emissions will be based on that combination of
factors which is likely to occur during the subject period and which result in the maximum
emissions.

(e) Test Condition. Samples shall be taken over such a period or periods as are necessary to
accurately determine the maximum emissions which will occur in any 24-hour period. No
changes in the operation shall be made, which would potentially increase emissions above that
determined by the most recent source test, until a new emission level has been estimated by
calculation and the results reported to the Director.

26
II.B.2.a.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit and
the above required testing methods.

II.B.2.a.3 Reporting:

All samples shall be analyzed and beryllium emissions shall be determined within 90 days after
the test. All determinations shall be reported to the Director by a registered letter dispatched
before the close of the next business day following such determination. There are no additional
reporting requirements for this provision except those specified in Section I of this permit.

Status: In compliance – The latest Comprehensive Performance Test (CPT) for beryllium was last
performed May 2-4, 2023. The CPT is conducted every 30 months.

Pollutant Limit (g/24 hrs) Result (g/24 hrs)
Beryllium 9.18 0.651

II.B.2.b Condition:

Emissions of Mercury Compounds shall be no greater than 3200 grams (7.1 lbs.) over any 24-
hour period when incinerating wastewater treatment plant sludge. [Authority granted under 40
CFR 61 Subpart E; condition originated in 40 CFR 61.52(b)].

II.B.2.b.1 Monitoring:

(a) Frequency: Performance testing shall be conducted when testing is required as outlined in
40 CFR Part 63, Subpart EEE, except as provided in paragraph (d) below.

(b) Notification. At least 30 days prior to conducting a stack test, the permittee shall notify the
Director of the date, time, and place of testing. A copy of the test protocol shall be provided
with the notification. The permittee and tester shall attend a pretest conference at least 30 days
prior to the test if determined necessary by the Director.

(c) Methods

(1) Sample location. The emissions point shall conform to the requirements of 40 CFR
60, Appendix A, Method 1.

(2) Pollutant concentrations. 40 CFR 60, Appendix A, Method 29 shall be used to test
emissions.

(3) Oxygen concentrations from the CEMS required by this permit shall be used to
correct the pollutant concentrations to 7% O2.

(4) Samples shall be taken over such a period or periods as are necessary to accurately
determine the maximum emissions which will occur in a 24-hour period. No changes in
the operation shall be made, which would potentially increase emissions above that
determined by the most recent source test, until the new emission level has been
estimated by calculation and the results reported to the Director.

27
(d) If mercury emissions exceed 1.6 kg per 24-hour period, the permittee shall monitor mercury
emissions at intervals of at least once per year as described in (c)(1)-(4) above.

II.B.2.b.2 Recordkeeping:

Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.b.3 Reporting:

All samples shall be analyzed and mercury emissions shall be determined within 30 days after
each stack test. Each determination shall be reported to the Director by a registered letter
dispatched within 15 calendar days following the date such determination is completed.

Status: In compliance – The latest Comprehensive Performance Test (CPT) for mercury was last
performed January 16, 2025. The CPT is conducted every 30 months.

Pollutant Limit (lb/24 hrs) Result (lb//24 hrs)
Mercury 7.1 0.0204
II.B.2.c Condition:

Emissions of Nickel Compounds shall be no greater than 5090 ug/dscm @ 7% O2. [Authority granted
under R307-401-8; condition originated in DAQE-AN107250026A-16].

II.B.2.c.1 Monitoring:

Stack testing shall be conducted as follows:

(a) Frequency. Performance testing shall be conducted when testing is required as outlined in 40 CFR
Part 63, Subpart EEE. Within 90 days of test completion, CHA shall submit the trial burn or
performance test results to the Director.

(b) Notification. At least 30 days prior to conducting a stack test, the permittee shall notify the Director
of the date, time, and place of testing. A copy of the test protocol shall be provided with the
notification. The permittee and tester shall attend a pretest conference at least 30 days prior to the test if
determined necessary by the Director.

(c) Methods

(1) Sample location. The emissions point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1.

(2) Pollutant concentrations. 40 CFR 60, Appendix A, Method 29 or EPA Publication SW-846,
Method 0060 shall be used to determine pollutant concentrations.

(3) Oxygen concentrations from the CEMS required by this permit shall be used to correct the
pollutant concentrations to 7% O2.

(d) Test Condition. Testing shall be conducted under conditions as required during a RCRA
performance test or trial burn, or 40 CFR 63 Subpart EEE comprehensive performance test.

28
II.B.2.c.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit and the
above required testing methods.

II.B.2.c.3 Reporting:

The results of stack testing shall be submitted to the Director within 90 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: In compliance – The latest Comprehensive Performance Test (CPT) for nickel was last
performed May 2-4, 2023. The CPT is conducted every 30 months.

Pollutant Limit (ug/dscm @ 7% O2) Result (ug/dscm @ 7% O2)
Nickel Compounds 5090 4.78
II.B.2.d Condition:

Emissions of Chlorine shall be no greater than 8.5 ppmdv @ 7% O2. [Authority granted under R307-
401-8; condition originated in DAQE-AN107250026A-16].

II.B.2.d.1 Monitoring:

Stack testing shall be conducted as follows:

(a) Frequency. Trial burn or performance testing shall be conducted when the testing is required as
outlined in 40 CFR Part 63, Subpart EEE. Within 90 days of test completion, CHA shall submit the
trial burn or performance test results to the Director.

(b) Notification. At least 30 days prior to conducting a stack test, the permittee shall notify the Director
of the date, time, and place of testing. A copy of the test protocol shall be provided with the
notification. The permittee and tester shall attend a pretest conference at least 30 days prior to the test if
determined necessary by the Director.

(c) Methods

(1) Sample location. The emissions point shall conform to the requirements of 40 CFR 60,
Appendix A, Method 1.

(2) Pollutant concentrations. 40 CFR 60, Appendix A, Methods 26A, 320 or 321 or EPA
Publication SW-846, Method 0050 shall be used to determine pollutant concentrations.

(3) Oxygen concentrations from the CEMS required by this permit shall be used to correct the
pollutant concentrations to 7% O2.

(d) Test Condition. Testing shall be conducted under conditions as required during a RCRA
performance test or trial burn, or 40 CFR 63 Subpart EEE comprehensive performance test.

29
II.B.2.d.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit and the
above required testing methods.

II.B.2.d.3 Reporting:

The results of stack testing shall be submitted to the Director within 90 days of completion of the
testing. Reports shall clearly identify results as compared to permit limits and indicate compliance
status. There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: In compliance – The latest Comprehensive Performance Test (CPT) for Chlorine was last
performed May 2-4, 2023. The CPT is conducted every 30 months.

Pollutant Limit (ppmdv @ 7% O2) Result (ppmdv @ 7% O2)
Chlorine 8.5 0.0319

II.B.2.e

Condition:

Emissions of NOx shall be no greater than 44.18 lbs./hr. averaged over 24 hours.

[Authority granted under R307-401-8; condition originated in DAQE-AN107250026A-16].

II.B.2.e.1 Monitoring:

The permittee shall install, calibrate, operate, and maintain a continuous emissions monitoring system
(CEM) in accordance with R 307-170. While the affected emission unit is operating, hourly NOx
emission rates expressed in lbs. per hour shall be determined in accordance with R307-170 using the
appropriate conversion factors. The applicable performance specification in R307-170 shall be 40 CFR
60, Appendix B, Performance Specification 6 - "Specifications and Test Procedures for Continuous
Emission Rate Monitoring Systems in Stationary Sources". The permittee shall use the hourly NOx
emission rates to compute 24-hour rolling averages.

Trial burn or performance testing shall be conducted when the testing is required as outlined in 40 CFR
Part 63, Subpart EEE. Within 90 days of test completion, CHA shall submit the trial burn or
performance test results to the Director.
II.B.2.e.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. The
permittee shall also maintain records as required by R307-170-8 except that these records will be
retained for 5 years as required by Provision I.S.1 of this permit.

30
II.B.2.e.3 Reporting:

The permittee shall comply with the reporting provisions in R307-170-7(5), R307-170-9 and Section I
of this permit. For the purposes of I.S.2.c of this permit, prompt for this condition shall be defined as
written notification by January 30, April 30, July 30, and October 30 for any deviations which occurred
during the quarter which ended 30 days earlier.

Status: Not Evaluated – Stack testing (CPT) for NOx was last performed May 2-4, 2023. The CPT is
conducted every 30 months. A CEM system that monitors real time NOx emissions has been
installed and operated. The CEM requirements are overseen by DAQ’s CEM specialist.

II.B.2.f Condition:

Emissions of SO2 shall be no greater than 91 ppmdv @ 7% O2 over an hourly rolling average.

[Authority granted under R307-401-8; condition originated in DAQE-AN107250026A-16].

II.B.2.f.1 Monitoring:

Monitoring shall be conducted as follows:

(I) Stack Testing:

(a) Frequency. Trial burn or performance testing shall be conducted when the testing is
required as outlined in 40 CFR Part 63, Subpart EEE. Within 90 days of test completion,
CHA shall submit the trial burn or performance test results to the Director.

(b) Notification. At least 30 days prior to conducting a stack test, the permittee shall
notify the Director of the date, time, and place of testing. A copy of the test protocol
shall be provided with the notification. The permittee and tester shall attend a pretest
conference at least 30 days prior to the test if determined necessary by the Director.

(c) Methods

(1) Sample location. The emissions point shall conform to the requirements of
40 CFR 60, Appendix A, Method 1.

(2) Pollutant concentrations. 40 CFR 60, Appendix A, Method 6, 6A, 6B or 6C
shall be used to determine pollutant concentrations.

(3) Oxygen concentrations from the CEMS required by this permit shall be used
to correct the pollutant concentrations to 7% O2.

(d) Test Condition. Testing shall be conducted under conditions as required during a
RCRA performance test or trial burn, or 40 CFR 63 Subpart EEE comprehensive
performance test.

(II) Continuous Emission Monitoring:

During each time period when used oil is fed to the affected emission unit, the permittee
shall monitor SO2 and O2 emissions using a continuous emission monitoring system
(CEMS) installed, calibrated, operated and maintained in accordance with R307-170.
31
The pollutant concentration shall be corrected to 7% oxygen using data from the oxygen
CEMS.

II.B.2.f.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit. The
permittee shall also maintain records as required by R307-170-8 except that these records will
be retained for 5 years as required by Provision I.S.1 of this permit. Additionally, the permittee
shall also record the start and end date and time of each time period that used oil is fed to the
affected emission unit.

II.B.2.f.3 Reporting:

The results of stack testing shall be submitted to the Director within 90 days of completion of
the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status. The permittee shall also comply with the reporting provisions in R307-170-
7(5), R307-170-9 and Section I of this permit. For the purposes of I.S.2.c of this permit, prompt
for this condition shall be defined as written notification by January 30, April 30, July 30, and
October 30 for any deviations which occurred during the quarter which ended 30 days earlier.

Status: Not Evaluated – Stack testing (CPT) for SO2 was last performed May 2-4, 2023. The CPT is
conducted every 30 months. A CEM system that monitors real time SO2 emissions has been
installed and operated. The CEM requirements are overseen by DAQ’s CEM specialist.

II.B.2.g Condition:

Visible emissions shall be no greater than 10 percent opacity.

[Authority granted under R307-401-8; condition originated in DAQE-AN107250026A-16].

II.B.2.g.1 Monitoring:

An opacity determination shall be conducted once in each quarter that the affected emission unit
is operated. The opacity determination shall be conducted in accordance with 40 CFR 60,
Appendix A, Method 9.

II.B.2.g.2 Recordkeeping:

Results from opacity observations and all data required by 40 CFR 60, Appendix A, Method 9
shall be recorded and maintained in accordance with Provision I.S.1 of this permit.

II.B.2.g.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – Quarterly opacity survey (Method 9) records were reviewed at time of the
inspection. Records are maintained electronically and hardcopy. All individuals that conduct the
opacity surveys are EPA Method 9 certified.

32
II.B.2.h Condition:

Hours of operation while waste material is incinerated shall be no greater than 8544 per 12
month rolling period.

[Authority granted under R307-401-8; condition originated in DAQE-AN107250026A-16].

II.B.2.h.1 Monitoring:

By the 15th day of each month, the permittee shall calculate the total hours of operation in the
previous 12 months for the affected emission unit. Records of hours of operation shall be kept
for all periods when the plant is in operation. The hours of operation shall be determined by the
supervisor monitoring and maintaining an operations log.

II.B.2.h.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.2.h.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The hours of operation while waste material is incinerated was 7,129
hours for the 12-month period March 2024 – February 2025. Operation hours for
incineration are tracked daily and are available for review on CHA’s reporting system
(ASEA Brown Boveri (ABB)).

II.B.2.i Condition:

If the emergency safety vent (ESV) opens when hazardous waste remains in the combustion
chamber (i.e., when the hazardous waste residence time has not expired) during an event other
than a malfunction as defined in the startup, shutdown, and malfunction plan such that
combustion gases are not treated as during the most recent trial burn or 40 CFR 63 Subpart EEE
comprehensive performance test (e.g., if the combustion gas bypasses any emission control
device that was operating during the trial burn or 40 CFR 63 Subpart EEE comprehensive
performance test), the permittee shall document in the operating record whether the incinerator
emissions remained in compliance with the emission standards of this permit during the ESV
opening event.

(i) ESV operating plan.

(A) The permittee shall keep current an ESV operating plan, comply with the operating
plan, and keep the plan in the operating record. Operating record means documentation
retained at the source for ready inspection by authorized officials of all information
required by this permit to document and maintain compliance with the requirements of
this permit, including data and information, reports, notifications, and communications
with the Director.

(B) The ESV operating plan shall provide detailed procedures for rapidly stopping the
waste feed, shutting down the combustor, and maintaining temperature and negative
pressure in the combustion chamber during the hazardous waste residence time, if
feasible. The plan shall include calculations and information and data documenting the
33
effectiveness of the plan's procedures for ensuring that combustion chamber temperature
and negative pressure are maintained as is reasonably feasible.

(ii) Corrective measures.

After any ESV opening that results in a failure to meet the emission standards of this permit, the
permittee shall investigate the cause of the ESV opening, take appropriate corrective measures
to minimize such future ESV openings.

[Authority granted under R307-401-8; condition originated in DAQE-AN107250026A-16].

II.B.2.i.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.i.2 Recordkeeping:

The permittee shall maintain records in accordance with provision I.S.1 of this permit. The
permittee shall also maintain records of the findings and corrective measures of any
investigation required by this condition.

II.B.2.i.3 Reporting:

The permittee shall comply with the reporting requirements in section I of this permit.
Additionally, the permittee shall submit to the Director a written report within 5 days of an
ESV opening that results in failure to meet the emission standards of this permit for the
affected emission unit. The report shall document the result of the investigation and corrective
measures taken.

Status: In compliance – The Emergency Safety Vent (ESV) Operating Plan, dated February 14,
2022, was last reviewed February 20, 2025. The plan is reviewed annually and ESV reports
are submitted as required. The last ESV report was submitted October 27, 2023.

II.B.2.j Condition:

The permittee shall comply with all applicable requirements of 40 CFR 63 Subpart EEE
including but not limited to (a)-(f) below:

(a) Emissions limits- (40 CFR §63.1219(a)). The permittee shall not discharge or cause
combustion gases to be emitted into the atmosphere that contain:

(1) Dioxin and furans:

(A) For incinerators equipped with either a waste heat boiler or dry air
pollution control system, either:

(i) Emissions of dioxins and furans shall not exceed 0.20 ng
TEQ/dscm, corrected to 7 percent oxygen; or

(ii) Emissions of dioxins and furans shall not exceed 0.40 ng
TEQ/dscm, corrected to 7 percent oxygen, provided that the
combustion gas temperature the inlet to the initial particulate matter
control device is 400 °F or lower based on the average of the test run
34
average temperatures. (For purposes of compliance, operation of a
wet particulate matter control device is presumed to meet the 400 °F
or lower requirement);

(B) Emissions of dioxins and furans shall not exceed 0.40 ng TEQ/dscm,
corrected to 7 percent oxygen, for incinerators not equipped with either a
waste heat boiler or dry air pollution control system;

(C) A source equipped with a wet air pollution control system followed by a
dry air pollution control system is not considered to be a dry air pollution
control system, and a source equipped with a dry air pollution control system
followed by a wet air pollution control system is considered to be a dry air
pollution control system for purposes of this standard;

(2) Mercury in excess of 130 micro-gm/dscm, corrected to 7 percent oxygen;

(3) Cadmium and lead in excess of 230 micro-gm/dscm, combined emissions, corrected to 7
percent oxygen;

(4) Arsenic, beryllium, and chromium in excess of 92 micro-gm/dscm, combined emissions,
corrected to 7 percent oxygen;

(5) For carbon monoxide and hydrocarbons, either:

(i) Carbon monoxide in excess of 100 parts per million by volume, over an hourly
rolling average (monitored continuously with a continuous emissions monitoring
system), dry basis and corrected to 7 percent oxygen. If you elect to comply with this
carbon monoxide standard rather than the hydrocarbon standard under paragraph
(a)(5)(ii), you must also document that, during the destruction and removal
efficiency (DRE) test runs or their equivalent as provided by §63.1206(b)(7),
hydrocarbons do not exceed 10 parts per million by volume during those runs, over
an hourly rolling average (monitored continuously with a continuous emissions
monitoring system), dry basis, corrected to 7 percent oxygen, and reported as
propane; or

(ii) Hydrocarbons in excess of 10 parts per million by volume, over an hourly rolling
average (monitored continuously with a continuous emissions monitoring system),
dry basis, corrected to 7 percent oxygen, and reported as propane;

(6) Hydrogen chloride and chlorine gas (total chlorine) in excess of 32 parts per
million by volume, combined emissions, expressed as a chloride (Cl(-)) equivalent,
dry basis and corrected to 7 percent oxygen; and

(7) Particulate matter in excess of 0.013 gr/dscf corrected to 7 percent oxygen.

(b) Destruction and removal efficiency standard (DRE)- (40 CFR §63.1219(c)).

(1) Except as provided in paragraph (b)(2), the permittee shall achieve a destruction
and removal efficiency (DRE) of 99.99% for each principle organic hazardous
constituent (POHC) designated under paragraph (b)(3). The permittee shall calculate
DRE for each POHC from the following equation:

35
DRE = [1 - (Wout / Win)] × 100%

Where:

Win = mass feedrate of one POHC in a waste feedstream; and

Wout = mass emission rate of the same POHC present in exhaust emissions
prior to release to the atmosphere.

(2) 99.9999% DRE. If you burn the dioxin-listed hazardous wastes F020, F021, F022,
F023, F026, or F027 (see 40 CFR §261.31), you must achieve a DRE of 99.9999% for
each POHC that you designate under paragraph (b)(3). You must demonstrate this
DRE performance on POHCs that are more difficult to incinerate than tetra-, penta-,
and hexachlorodibenzo-p-dioxins and dibenzofurans. You must use the equation in
paragraph (b)(1) to calculate DRE for each POHC.

In addition, you must notify the Director of your intent to incinerate hazardous wastes F020,
F021, F022, F023, F026, or F027.

(3) Principal organic hazardous constituent (POHC).

(i) You must treat each POHC in the waste feed that you specify under paragraph
(b)(3)(ii) to the extent required by paragraphs (b)(1) and (b)(2).

(ii) You must specify one or more POHCs that are representative of the most
difficult to destroy organic compounds in your hazardous waste feed stream.
You must base this specification on the degree of difficulty of incineration of
the organic constituents in the hazardous waste and on their concentration or
mass in the hazardous waste feed, considering the results of hazardous waste
analyses or other data and information.

(c) Significant figures- (40 CFR 63.1219 (d)).

(d) Compliance with Standards- (40 CFR 63.1206(b)).

(e) Operating requirements- (40 CFR 63.1206 (c)).

(f) General Provisions- The permittee shall comply with all applicable requirements of 40 CFR 63
Subpart A as given in Table 1 of 40 CFR 63 Subpart EEE.

[Authority granted under 40 CFR 63 Subpart EEE; condition originated in 40 CFR 63 Subpart EEE]

II.B.2.j.1 Monitoring:

The permittee shall comply with all applicable performance testing and monitoring requirements
of 40 CFR 63 Subpart EEE including but not limited to those given in 40 CFR 63.1207, 1208,
1209, and 1215.

The permittee shall comply with all applicable requirements of 40 CFR 63 Subpart A as given in
Table 1 of 40 CFR 63 Subpart EEE.

36
II.B.2.j.2 Recordkeeping:

The permittee shall comply with the recordkeeping requirements in Section I of this permit and
any additional recordkeeping requirements of:

(a) 40 CFR 63 Subpart EEE including but not limited to those given in 40 CFR 63.1211.

(b) 40 CFR 63 Subpart A as given in Table 1 of 40 CFR 63 Subpart EEE.

II.B.2.j.3 Reporting:

The permittee shall comply with the reporting requirements in Section I of this permit and any
additional reporting and notification requirements of:

(a) 40 CFR 63 Subpart EEE, as applicable, including but not limited to those given in 40 CFR 63.1207,
1210, 1211, 1212 and 1215.

(b) 40 CFR 63 Subpart A as given in Table 1 of 40 CFR 63 Subpart EEE.

Status: In compliance – There were no exceedances since the last inspection. Therefor no Excessive
Exceedance Self reports were required to be submitted. The CPT was conducted on May 2-4,
2023. The CPT is conducted every 30 months. The Focus Environmental CPT report dated July
2023, and the NOC CPT report dated August 2, 2023, were both submitted. Data from both
reports is as follows:

Test Date RM/Pollutant DAQ Results Test Results Limits
May 2-4, 2023 26A/PM 0.001* 0.001* 0.013*
2.28** 2.28** 34**
26A/HCL+CL2 0.79++ 0.79++ 32++
26A/CL2 0.0159++ 0.0159++ 8.5++
29/Pb+Cd <4.7 -- <4.7-- 130--
29/As+Be+Cr <5.3-- <5.3-- 92--
January 16,
2025
29/Hg 31-- 8.80-- 130--
0.1 lb./24hr 0.1 lb./24hr 7.2 lb./24hr
55 g/24hr 55 g/24hr 3200g/24hr
23/DF 0.035 II 0.035 II 0.40 II
23/0DCB X 99.9999% 99.9999% 99.9999%
CEM/CO III 1.8++ 100++
CEM/THC III 0.28++ 10++

*
gr/dscf@7%O2

**
mg/dscm@7%O
2

++
ppmvd@7%O2

--
ug/dscm@7%O2

37

II
ng/dscm@7%O2
TEQ

X
Orthodichlorobenzene (ODCB) was used as a surrogate for demonstrating the PCB DRE
requirement. See stack test report for more details.

III
CO, THC, SOx, and NOx emissions were determined using the source's CEM data. See
RATA files for specifics.

II.B.2.k

Condition:

(i) The permittee shall implement a written startup, shutdown, and malfunction plan that
describes, in detail, procedures for operating and maintaining the affected emission unit during
periods of startup, shutdown, and malfunction; a program of corrective action for
malfunctioning processes; and air pollution control and monitoring equipment used to comply
with the standards for the affected emission unit.

(ii) During periods of startup, shutdown, and malfunction, the permittee shall operate and
maintain the affected emission unit (including associated air pollution control and monitoring
equipment) in accordance with the procedures specified in the startup, shutdown, and
malfunction plan developed under paragraph (i) of this condition.

(iii) The permittee shall maintain at the affected emission unit a current startup, shutdown, and
malfunction plan and shall make the plan available upon request for inspection and copying by
the Director. In addition, if the startup, shutdown, and malfunction plan is subsequently revised
as provided in paragraph (v) of this condition, the permittee shall maintain at the affected
emission unit each previous (i.e., superseded) version of the startup, shutdown, and malfunction
plan, and shall make each such previous version available for inspection and copying by the
Director for a period of 5 years after revision of the plan. If at any time after adoption of a
startup, shutdown, and malfunction plan the affected emission unit ceases operation or is
otherwise no longer subject to the provisions of 40 CFR 63, the permittee shall retain a copy of
the most recent plan for 5 years from the date the affected emission unit ceases operation or is
no longer subject to 40 CFR 63 and shall make the plan available upon request for inspection
and copying by the Director.

(iv) To satisfy the requirements of this section to develop a startup, shutdown, and malfunction
plan, the permittee may use the affected emission unit's standard operating procedures (SOP)
manual, or an Occupational Safety and Health Administration (OSHA) or other plan, provided
the alternative plans meet all the requirements of this section and are made available for
inspection when requested by the Director.

(v) The permittee may periodically revise the startup, shutdown, and malfunction plan for the
affected emission unit as necessary to satisfy the requirements of 40 CFR 63 or to reflect
changes in equipment or procedures at the affected emission unit. However, each such revision
to a startup, shutdown, and malfunction plan shall be reported in the semiannual report required
by reporting. If the startup, shutdown, and malfunction plan fails to address or inadequately
addresses an event that meets the characteristics of a malfunction but was not included in the
startup, shutdown, and malfunction plan at the time the permittee developed the plan, the
permittee shall revise the startup, shutdown, and malfunction plan within 45 days after the event
38
to include detailed procedures for operating and maintaining the affected emission unit during
similar malfunction events and a program of corrective action for similar malfunctions of
process or air pollution control and monitoring equipment. In the event that the permittee makes
any revision to the startup, shutdown, and malfunction plan which alters the scope of the
activities at the affected emission unit which are deemed to be a startup, shutdown, malfunction,
or otherwise modifies the applicability of any emission limit, work practice requirement, or
other requirement in a standard established under 40 CFR 63, the revised plan shall not take
effect until after the permittee has provided a written notice describing the revision to the
permitting authority.

(vi) Any revisions made to the startup, shutdown, and malfunction plan in accordance with the
procedures established by 40 CFR 63 shall not be deemed to constitute permit revisions under
this permit. Moreover, none of the procedures specified by the startup, shutdown, and
malfunction plan for an affected emission unit shall be deemed to fall within the permit shield
provision in this permit.

[Authority granted under R307-401-8 and 40 CFR 63.6(e)(3); condition originated in DAQE-
AN107250026A-16 and 40 CFR 63.6(e)(3)].

II.B.2.k.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.k.2 Recordkeeping:

The permittee shall maintain the following records in accordance with section I.S.1 of this
permit:

(i) The occurrence and duration of each startup, shutdown, or malfunction of the operation;

(ii) The occurrence and duration of each malfunction of the required air pollution control
and monitoring equipment;

(iii) All required maintenance performed on the air pollution control and monitoring
equipment;

(iv) Actions taken during periods of startup, shutdown, and malfunction (including
corrective actions to restore malfunctioning process and air pollution control and
monitoring equipment to its normal or usual manner of operation) when such actions are
different from the procedures specified in the startup, shutdown, and malfunction plan;

(v) All information necessary to demonstrate conformance with the affected emission unit's
startup, shutdown, and malfunction plan when all actions taken during periods of startup,
shutdown, and malfunction (including corrective actions to restore malfunctioning process
and air pollution control and monitoring equipment to its normal or usual manner of
operation) are consistent with the procedures specified in such plan. (The information
needed to demonstrate conformance with the startup, shutdown, and malfunction plan may
be recorded using a "checklist," or some other effective form of recordkeeping, in order to
minimize the recordkeeping burden for conforming events); and

(vi) Each period during which a CMS is malfunctioning or inoperative (including out-of-
control periods).

39
II.B.2.k.3 Reporting:

The permittee shall comply with the reporting requirements in Section I of this permit. In
addition, the permittee shall comply with the following reporting requirements.

(i) If actions taken by the permittee during a startup, shutdown, or malfunction of the
affected emission unit (including actions taken to correct a malfunction) are consistent with
the procedures specified in the startup, shutdown, and malfunction plan, the permittee shall
state such information in a startup, shutdown, and malfunction report. Reports shall only be
required if a startup, shutdown, or malfunction occurred during the reporting period, and
they must include the number, duration, and a brief description of each startup, shutdown,
or malfunction. The startup, shutdown, and malfunction report shall consist of a letter,
containing the name, title, and signature of the permittee or other responsible official who
is certifying its accuracy, that shall be submitted to the Director semiannually. The startup,
shutdown, and malfunction report shall be delivered or postmarked by the 30th day
following the end of each calendar half.

(ii) Immediate startup, shutdown, and malfunction reports. Any time an action taken by the
permittee during a startup, shutdown, or malfunction (including actions taken to correct a
malfunction) is not consistent with the procedures specified in the affected emission unit's
startup, shutdown, and malfunction plan, the permittee shall report the actions taken for
that event within 2 working days after commencing actions inconsistent with the plan
followed by a letter within 7 working days after the end of the event. The immediate report
required under this paragraph shall consist of a telephone call (or facsimile [FAX]
transmission) to the Director within 2 working days after commencing actions inconsistent
with the plan, and it shall be followed by a letter, delivered or postmarked within 7 working
days after the end of the event, that contains the name, title, and signature of the permittee
or other responsible official who is certifying its accuracy, explaining the circumstances of
the event, the reasons for not following the startup, shutdown, and malfunction plan, and
whether any excess emissions and/or parameter monitoring exceedances are believed to
have occurred.

Status: In compliance – The most recent Startup, Shutdown and Malfunction Plan (SSMP), dated April 11, 2022, was reviewed and discussed at time of the inspection. The plan is reviewed annually. Event logs are kept by operators, and system checks are used to help ensure that the SSMP is followed by automatically locking out production in the event that operating parameters are not met. The most recent semi-annual startup, shutdown and malfunction report (SSMR), dated January 6, 2025, was received by the DAQ on January 9, 2025.

II.B.3 Conditions on Offsite Material Management Unit (GRP).

II.B.3.a Condition:

(1) Operation and maintenance requirements.

(i) At all times, including periods of startup, shutdown, and malfunction, the
permittee shall operate and maintain the affected emission unit, including associated
air pollution control equipment and monitoring equipment, in a manner consistent
with safety and good air pollution control practices for minimizing emissions to the
levels required by this permit, i.e., meet the emission standard or comply with the
startup, shutdown, and malfunction plan. Determination of whether such operation
and maintenance procedures are being used will be based on information available to
40
the Director which may include, but is not limited to, monitoring results, review of
operation and maintenance procedures (including the startup, shutdown, and
malfunction plan required in paragraph (2) of this section), review of operation and
maintenance records, and inspection of the source.

(ii) Malfunctions shall be corrected as soon as practicable after their occurrence in
accordance with the startup, shutdown, and malfunction plan required in paragraph
(2) of this section. To the extent that an unexpected event arises during a startup,
shutdown, or malfunction, the permittee shall comply by minimizing emissions
during such a startup, shutdown, and malfunction event consistent with safety and
good air pollution control practices.

(2) Startup, Shutdown, and Malfunction Plan.

(i) The permittee shall implement a written startup, shutdown, and malfunction plan
that describes, in detail, procedures for operating and maintaining the affected
emission unit during periods of startup, shutdown, and malfunction; a program of
corrective action for malfunctioning process; and air pollution control and monitoring
equipment used to comply with this condition.

(ii) During periods of startup, shutdown, and malfunction, the permittee shall operate
and maintain the affected emission unit (including associated air pollution control and
monitoring equipment) in accordance with the procedures specified in the startup,
shutdown, and malfunction plan developed under paragraph (2)(i) of this section.

(iii) The permittee shall maintain at the affected emission unit a current startup,
shutdown, and malfunction plan and shall make the plan available upon request for
inspection and copying by the Director. In addition, if the startup, shutdown, and
malfunction plan is subsequently revised as provided in paragraph (2)(v) of this
section, the permittee shall maintain at the affected emission unit each previous (i.e.,
superseded) version of the startup, shutdown, and malfunction plan, and shall make
each such previous version available for inspection and copying by the Director for a
period of 5 years after revision of the plan. If at any time after adoption of a startup,
shutdown, and malfunction plan the affected emission unit ceases operation or is
otherwise no longer subject to the provisions of 40 CFR 63, the permittee shall retain
a copy of the most recent plan for 5 years from the date the source ceases operation or
is no longer subject to 40 CFR 63 and shall make the plan available upon request for
inspection and copying by the Director.

(iv) To satisfy the requirements of this section to develop a startup, shutdown, and
malfunction plan, the permittee may use the affected emission unit's standard
operating procedures (SOP) manual, or an Occupational Safety and Health
Administration (OSHA) or other plan, provided the alternative plans meet all the
requirements of this section and are made available for inspection when requested by
the Director.

(v) The permittee may periodically revise the startup, shutdown, and malfunction
plan for the affected emission unit as necessary to satisfy the requirements of 40 CFR
63 or to reflect changes in equipment or procedures at the affected emission unit. The
permittee may make such revisions to the startup, shutdown, and malfunction plan
without prior approval by the permitting authority. However, each such revision to a
startup, shutdown, and malfunction plan shall be reported in the semiannual report
required under reporting. If the startup, shutdown, and malfunction plan fails to
41
address or inadequately addresses an event that meets the characteristics of a
malfunction but was not included in the startup, shutdown, and malfunction plan at
the time the permittee developed the plan, the permittee shall revise the startup,
shutdown, and malfunction plan within 45 days after the event to include detailed
procedures for operating and maintaining the affected emission unit during similar
malfunction events and a program of corrective action for similar malfunctions of
process or air pollution control and monitoring equipment. In the event that the
permittee makes any revision to the startup, shutdown, and malfunction plan which
alters the scope of the activities at the affected emission unit which are deemed to be
a startup, shutdown, malfunction, or otherwise modifies the applicability of any
emission limit, work practice requirement, or other requirement in a standard
established under 40 CFR 63, the revised plan shall not take effect until after the
permittee has provided a written notice describing the revision to the permitting
authority.

(vi) Any revisions made to the startup, shutdown, and malfunction plan in accordance
with the procedures established by 40 CFR 63 shall not be deemed to constitute
permit revisions under this permit. Moreover, none of the procedures specified by the
startup, shutdown, and malfunction plan for an affected emission unit shall be
deemed to fall within the permit shield provision in this permit. [Authority granted
under 40 CFR 63 Subpart A; condition originated in 40 CFR 63 Subpart A]

II.B.3.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.3.a.2 Recordkeeping:

The permittee shall comply with the following recordkeeping requirements:

(a) General recordkeeping requirements.

(1) The permittee shall maintain files of all information (including all reports and
notifications) required by 40 CFR 63 recorded in a form suitable and readily available
for expeditious inspection and review. The files shall be retained for at least 5 years
following the date of each occurrence, measurement, maintenance, corrective action,
report, or record. At a minimum, the most recent 2 years of data shall be retained on
site. The remaining 3 years of data may be retained off site. Such files may be
maintained on microfilm, on a computer, on computer floppy disks, on magnetic tape
disks, or on microfiche.

(2) The permittee shall maintain relevant records of-

(i) The occurrence and duration of each startup, shutdown, or malfunction of
operation (i.e., process equipment);

(ii) The occurrence and duration of each malfunction of the required air pollution
control and monitoring equipment;

(iii) Actions taken during periods of startup, shutdown, and malfunction (including
corrective actions to restore malfunctioning process and air pollution control and
monitoring equipment to its normal or usual manner of operation) when such
actions are different from the procedures specified in the affected emission unit's
42
startup, shutdown, and malfunction plan;

(iv) All information necessary to demonstrate conformance with the affected
emission unit's startup, shutdown, and malfunction plan when all actions taken
during periods of startup, shutdown, and malfunction (including corrective actions
to restore malfunctioning process and air pollution control and monitoring
equipment to its normal or usual manner of operation) are consistent with the
procedures specified in such plan. (The information needed to demonstrate
conformance with the startup, shutdown, and malfunction plan may be recorded
using a "checklist," or some other effective form of recordkeeping, in order to
minimize the recordkeeping burden for conforming events).

II.B.3.a.3 Reporting:

The permittee shall comply with the reporting requirements in Section I of this permit. In
addition, the permittee shall comply with the following reporting requirements.

(a) Applicability and general information. The permittee shall send a copy of each report
submitted to the Director to Region 8 of the EPA to the address given in Section I of this
permit.

(b) General reporting requirements.

(i) Periodic startup, shutdown, and malfunction reports. If actions taken by the
permittee during a startup, shutdown, or malfunction (including actions taken to
correct a malfunction) are consistent with the procedures specified in the source's
startup, shutdown, and malfunction plan, the permittee shall state such information
in a startup, shutdown, and malfunction report. Reports shall only be required if a
startup, shutdown, or malfunction occurred during the reporting period, and they
shall include the number, duration, and a brief description of each startup,
shutdown, or malfunction. The startup, shutdown, and malfunction report shall
consist of a letter, containing the name, title, and signature of the permittee or other
responsible official who is certifying its accuracy, that shall be submitted to the
Director semiannually (or on a more frequent basis if specified otherwise in this
condition). The startup, shutdown, and malfunction report shall be delivered or
postmarked by the 30th day following the end of each calendar half (or other
calendar reporting period, as appropriate).

(ii) Immediate startup, shutdown, and malfunction reports. Any time an action taken
by the permittee during a startup, shutdown, or malfunction (including actions
taken to correct a malfunction) is not consistent with the procedures specified in the
affected emission unit's startup, shutdown, and malfunction plan, the permittee
shall report the actions taken for that event within 2 working days after
commencing actions inconsistent with the plan followed by a letter within 7
working days after the end of the event. The immediate report required under this
paragraph shall consist of a telephone call (or facsimile [FAX] transmission) to the
Director within 2 working days after commencing actions inconsistent with the
plan, and it shall be followed by a letter, delivered or postmarked within 7 working
days after the end of the event, that contains the name, title, and signature of the
permittee or other responsible official who is certifying its accuracy, explaining the
circumstances of the event, the reasons for not following the startup, shutdown, and
malfunction plan, and whether any excess emissions and/or parameter monitoring
exceedances are believed to have occurred.
43
Status: In compliance – See status of condition II.B.2.k.

II.B.3.b Condition:

40 CFR 63 Subpart DD

(I) Affected Equipment

(a)Equipment leaks. This condition applies to all equipment components in the
permittee's facility that meet the following three criteria.

(1)The equipment component is a pump, pressure relief device, sampling
connection system, open-ended valve or line, valve, connector, or
instrumentation system;

(2) The equipment component contains or contacts off-site material having a
total HAP concentration equal to or greater than 10 percent by weight; and

(3) The equipment component is intended to operate for 300 hours or more
during a calendar year in off-site material service.

(II) Standards: General.

(a) The permittee shall demonstrate compliance with the requirements of sections
III through IX of this condition as required in 40 CFR 61.05, except as provided
in sections X and XI of this condition.

(b) Compliance with this condition will be determined by review of records,
review of performance test results, and inspection using the methods and
procedures specified in monitoring.

(c) Each piece of equipment to which this condition applies shall be marked in
such a manner that it can be distinguished readily from other pieces of equipment.

(III) Standards: Pumps.

(a)

(1) Each pump shall be monitored monthly to detect leaks by the methods
specified in paragraph (a) of monitoring.

(2) Each pump shall be checked by visual inspection each calendar week
for indications of liquids dripping from the pump seal.

(b)

(1) If an instrument reading of 10,000 ppm or greater is measured, a leak is
detected.

(2) If there are indications of liquids dripping from the pump seal, a leak is
detected.

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(c)

(1) When a leak is detected, it shall be repaired as soon as practicable, but not
later than 15 calendar days after it is detected, except as provided in section IX
of this condition.

(2) A first attempt at repair shall be made no later than 5 calendar days after each
leak is detected.

(IV) Standards: Pressure relief devices in gas/vapor service.

(a) Except during pressure releases, each pressure relief device in gas/vapor service shall
be operated with no detectable emissions, as indicated by an instrument reading of less
than 500 ppm above background, as measured by the method specified in paragraph (b) of
monitoring.

(b)

(1) After each pressure release, the pressure relief device shall be returned to a
condition of no detectable emissions, as indicated by an instrument reading of less
than 500 ppm above background, as soon as practicable, but no later than 5
calendar days after each pressure release, except as provided in section IX of this
condition.

(2) No later than 5 calendar days after the pressure release, the pressure relief
device shall be monitored to confirm the condition of no detectable emissions, as
indicated by an instrument reading of less than 500 ppm above background, as
measured by the method specified in paragraph (b) of monitoring.

(V) Standards: Sampling connecting systems.

(a) In-situ sampling systems and sampling systems without purges are exempt from the
requirements of paragraphs (a) and (b) 40 CFR 61.242-5.

(VI) Standards: Open-ended valves or lines.

(a)

(1) Each open-ended valve or line shall be equipped with a cap, blind flange, plug,
or a second valve.

(2) The cap, blind flange, plug, or second valve shall seal the open end at all times
except during operations requiring process fluid flow through the open-ended
valve or line.

(b) Each open-ended valve or line equipped with a second valve shall be operated in a
manner such that the valve on the process fluid end is closed before the second valve is
closed.

(c) When a double block and bleed system is being used, the bleed valve or line may
remain open during operations that require venting the line between the block valves but
shall comply with paragraph (a) at all other times.

45
(d) Open-ended valves or lines containing materials which would autocatalytically
polymerize or would present an explosion, serious overpressure, or other safety hazard if
capped or equipped with a double block and bleed system as specified in paragraphs (a)
through (c) of this section are exempt from the requirements of paragraphs (a) through (c)
of this section.

(VII) Standards: Valves.

(a) Each valve shall be monitored monthly to detect leaks by the method specified in
paragraph (a) of monitoring and shall comply with paragraphs (b)-(e), except as provided
in paragraphs (f) and (g) of this section, and sections X and XI of this condition.

(b) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected.

(c)

(1) Any valve for which a leak is not detected for 2 successive months may be
monitored the first month of every quarter, beginning with the next quarter, until a
leak is detected.

(2) If a leak is detected, the valve shall be monitored monthly until a leak is not
detected for 2 successive months.

(d)
(1) When a leak is detected, it shall be repaired as soon as practicable, but no later
than 15 calendar days after the leak is detected, except as provided in section IX
of this condition.

(2) A first attempt at repair shall be made no later than 5 calendar days after each
leak is detected.

(e) First attempts at repair include, but are not limited to, the following best practices
where practicable:

(1) Tightening of bonnet bolts;

(2) Replacement of bonnet bolts;

(3) Tightening of packing gland nuts; and

(4) Injection of lubricant into lubricated packing.

(f) Any valve that is designated, as described in paragraph (d)(1) of Section II of
recordkeeping, as an unsafe-to-monitor valve is exempt from the requirements of
paragraph (a) if:

(1) The permittee of the valve demonstrates that the valve is unsafe to monitor
because monitoring personnel would be exposed to an immediate danger as a
consequence of complying with paragraph (a); and

(2) The permittee of the valve has a written plan that requires monitoring of the
valve as frequent as practicable during safe-to-monitor times.

46
(g) Any valve that is designated, as described in paragraph (d)(2) of section II of
recordkeeping, as a difficult-to-monitor valve is exempt from the requirements of
paragraph (a) if:

(1) The permittee of the valve demonstrates that the valve cannot be monitored
without elevating the monitoring personnel more than 2 meters above a support
surface;

(2) The process unit within which the valve is located is an existing process unit;
and

(3) The permittee of the valve follows a written plan that requires monitoring of
the valve at least once per calendar year.

(VIII) Standards: Pressure relief services in liquid service and connectors.

(a) If evidence of a potential leak is found by visual, audible, olfactory, or any other
detection method at pressure relief devices in liquid service and connectors, the permittee
shall follow either one of the following procedures:

(1) The permittee shall monitor the equipment within 5 days by the method
specified in paragraph (a) of monitoring and shall comply with the requirements
of paragraphs (b) through (d) of this section.

(2) The permittee shall eliminate the visual, audible, olfactory, or other indication
of a potential leak.

(b) If an instrument reading of 10,000 ppm or greater is measured, a leak is detected.

(c)

(1) When a leak is detected, it shall be repaired as soon as practicable, but not
later than 15 calendar days after it is detected, except as provided in section IX of
this condition.

(2) The first attempt at repair shall be made no later than 5 calendar days after
each leak is detected.

(d) First attempts at repair include, but are not limited to, the best practices described
under paragraph (e) of section VII of this condition.

(IX) Standards: Delay of repair.

(a) Delay of repair of equipment for which leaks have been detected will be allowed if
repair within 15 days is technically infeasible without a process unit shutdown. Repair of
this equipment shall occur before the end of the next process unit shutdown.

(b) Delay of repair of equipment for which leaks have been detected will be allowed for
equipment that is isolated from the process and that does not remain in VHAP service.

(c) Delay of repair for valves will be allowed if:

47
(1) The permittee demonstrates that emissions of purged material resulting from
immediate repair are greater than the fugitive emissions likely to result from delay
of repair, and

(2) When repair procedures are effected, the purged material is collected and
destroyed or recovered in a control device complying with 40 CFR 61.242-11.

(d) Delay of repair for pumps will be allowed if:

(1) Repair requires the use of a dual mechanical seal system that includes a barrier
fluid system, and

(2) Repair is completed as soon as practicable, but not later than 6 months after
the leak was detected.

(e) Delay of repair beyond a process unit shutdown will be allowed for a valve if valve
assembly replacement is necessary during the process unit shutdown, valve assembly
supplies have been depleted, and valve assembly supplies had been sufficiently stocked
before the supplies were depleted. Delay of repair beyond the next process unit shutdown
will not be allowed unless the next process unit shutdown occurs sooner than 6 months
after the first process unit shutdown.

(X) Alternative standards for valves in VHAP service- allowable percentage of valves leaking.

(a) The permittee may elect to have all valves within a process unit comply with an
allowable percentage of valves leaking of equal to or less than 2.0 percent.

(b) The following requirements shall be met if the permittee decides to comply with an
allowable percentage of valves leaking:

(1)The permittee shall notify the Director that the permittee has elected to have all
valves within a process unit to comply with the allowable percentage of valves
leaking before implementing this alternative standard, as specified in paragraph
(c) Section II of reporting.

(2) A performance test as specified in paragraph (c) of this section shall be
conducted initially upon designation, annually, and at other times requested by the
Director.

(3) If a valve leak is detected, it shall be repaired in accordance with paragraphs
(d) and (e) of section VII of this condition.

(c) Performance tests shall be conducted in the following manner:

(1) All valves in VHAP service within the process unit shall be monitored within
1 week by the methods specified in paragraph (a) of monitoring.

(2)If an instrument reading of 10,000 ppm or greater is measured, a leak is
detected.

(3) The leak percentage shall be determined by dividing the number of valves in
VHAP service for which leaks are detected by the number of valves in VHAP
48
service within the process unit.

(d) If the permittee elects to have all valves comply with this alternative standard, the
permittee shall not have a process unit with a leak percentage greater than 2.0 percent.

(e) If the permittee decides no longer to comply with section X of this condition, the
permittee shall notify the Director in writing that the work practice standard described in
paragraphs (a)-(e) of section VII of this condition will be followed.

(XI) Alternative standards for valves in VHAP service-skip period leak detection and repair.

(a)

(1) The permittee may elect for all valves within a process unit to comply with
one of the alternative work practices specified in paragraphs (b)(2) and (3) of this
section.

(2) The permittee shall notify the Director before implementing one of the
alternative work practices, as specified in paragraph (c) of section II of reporting.

(b)

(1) The permittee shall comply initially with the requirements for valves, as
described in section VII of this condition.

(2) After 2 consecutive quarterly leak detection periods with the percentage of
valves leaking equal to or less than 2.0, the permittee may begin to skip one of the
quarterly leak detection periods for the valves in VHAP service.

(3) After five consecutive quarterly leak detection periods (or two consecutive
quarterly leak detection samples followed by 3 consecutive semiannual leak
detection samples) with the percentage of valves leaking equal to or less than 2.0,
the permittee may begin to skip three of the quarterly leak detection periods for
the valves in VHAP service.

(4) If the percentage of valves leaking is greater than 2.0, the permittee shall
comply with the requirements as described in section VII of this condition but
may again elect to use this section.

[Authority granted under 40 CFR 63.691 - Affected Equipment; condition originated in 40 CFR
63 Subpart DD]

II.B.3.b.1 Monitoring:

(a) Monitoring shall comply with the following requirements:

(1) Monitoring shall comply with Method 21 of Appendix A of 40 CFR part 60.

(2) The detection instrument shall meet the performance criteria of Method 21.

(3) The instrument shall be calibrated before use on each day of its use by the
procedures specified in Method 21.

49
(4) Calibration gases shall be:

(i) Zero air (less than 10 ppm of hydrocarbon in air); and

(ii) A mixture of methane or n-hexane and air at a concentration of approximately,
but less than, 10,000 ppm methane or n-hexane.

(5) The instrument probe shall be traversed around all potential leak interfaces as close to
the interface as possible as described in Method 21.

(b) When equipment is tested for compliance with or monitored for no detectable emissions, the
permittee shall comply with the following requirements:

(1) The requirements of paragraphs (a) (1) through (4) shall apply.

(2) The background level shall be determined, as set forth in Method 21.

(3) The instrument probe shall be traversed around all potential leak interfaces as close to
the interface as possible as described in Method 21.

(4) The arithmetic difference between the maximum concentration indicated by the
instrument and the background level is compared with 500 ppm for determining
compliance.

(c)

(1) Each piece of equipment within a process unit that can conceivably contain equipment
in VHAP service is presumed to be in VHAP service unless the permittee demonstrates
that the piece of equipment is not in VHAP service. For a piece of equipment to be
considered not in VHAP service, it shall be determined that the percent VHAP content can
be reasonably expected never to exceed 10 percent by weight. For purposes of
determining the percent VHAP content of the process fluid that is contained in or contacts
equipment, procedures that conform to the methods described in ASTM Method D-2267
(incorporated by the reference as specified in 40 CFR 61.18) shall be used.

(2)

(i) The permittee may use engineering judgment rather than the procedures in
paragraph (c)(1) of this section to demonstrate that the percent VHAP content
does not exceed 10 percent by weight, provided that the engineering judgment
demonstrates that the VHAP content clearly does not exceed 10 percent by
weight. When the permittee and the Director do not agree on whether a piece of
equipment is not in VHAP service, however, the procedures in paragraph (c)(1) of
this section shall be used to resolve the disagreement.

(ii) If the permittee determines that a piece of equipment is in VHAP service, the
determination can be revised only after following the procedures in paragraph
(c)(1) of this section.

(3) Samples used in determining the percent VHAP content shall be representative of the
process fluid that is contained in or contacts the equipment.

50
II.B.3.b.2 Recordkeeping:

(I) General Requirements

(a) The permittee shall comply with the recordkeeping requirements in 40 CFR 63.10
under 40 CFR 63 subpart A-General Provisions that are applicable to this condition as
specified in Table 2 of 40 CFR 63 Subpart DD.

(b) The permittee shall maintain the records in accordance with the requirements of 40
CFR 63.10 of 40 CFR 63 and Section I.S.1 of this permit.

(II) Specific Requirements

(a) When each leak is detected as specified in sections III, VII, and VIII of this condition,
the following requirements apply:

(1) A weatherproof and readily visible identification, marked with the equipment
identification number, shall be attached to the leaking equipment.

(2) The identification on a valve may be removed after it has been monitored for
2 successive months as specified in paragraph (c) section VII of this condition and
no leak has been detected during those 2 months.

(3) The identification on equipment, except on a valve, may be removed after it
has been repaired.

(b) When each leak is detected as specified in sections III, VII, and VIII of this condition,
the following information shall be recorded in a log and shall be kept for 5 years in a
readily accessible location:

(1) The instrument and operator identification numbers and the equipment
identification number.

(2) The date the leak was detected and the dates of each attempt to repair the leak.

(3) Repair methods applied in each attempt to repair the leak.

(4) "Above 10,000" if the maximum instrument reading measured by the methods
specified in monitoring after each repair attempt is equal to or greater than 10,000
ppm.
(5) "Repair delayed" and the reason for the delay if a leak is not repaired within
15 calendar days after discovery of the leak.

(6) The signature of the permittee (or designate) whose decision it was that repair
could not be effected without a process shutdown.

(7) The expected date of successful repair of the leak if a leak is not Repaired
within 15 calendar days unrepaired.

(8) Dates of process unit shutdowns that occur while the equipment is unrepaired.

(9) The date of successful repair of the leak.

51
(c) The following information pertaining to all equipment to which a standard applies
shall be recorded in a log that is kept in a readily accessible location:

(1) A list of identification numbers for equipment (except welded fittings) subject
to the requirements of this condition.

(2) A list of equipment identification numbers for pressure relief devices required
to comply with paragraph (a) section IV of this condition.

(3)

(i) The dates of each compliance test required in section IV of this condition.

(ii) The background level measured during each compliance test if that
measurement did not assume a zero-background level.

(iii) The maximum instrument reading measured at the equipment during each
compliance test.

(d) The following information pertaining to all valves subject to the requirements of
paragraphs (f) and (g) of section VII of this condition shall be recorded in a log that is
kept in a readily accessible location:

(1) A list of identification numbers for valves that are designated as unsafe to
monitor, an explanation for each valve stating why the valve is unsafe to monitor,
and the plan for monitoring each valve.

(2) A list of identification numbers for valves that are designated as difficult to
monitor, an explanation for each valve stating why the valve is difficult to
monitor, and the planned schedule for monitoring each valve.

(e) The following information shall be recorded for valves complying with section XI of
this condition:

(1) A schedule of monitoring.

(2) The percent of valves found leaking during each monitoring period.

(f) The following information shall be recorded in a log that is kept in a readily accessible
location for use in determining exemptions as provided in the applicability section of this
condition:

(1) An analysis demonstrating the design capacity of the process unit, and

(2) An analysis demonstrating that equipment is not in VHAP service.

(g) Information and data used to demonstrate that a piece of equipment is not in VHAP
service shall be recorded in a log that is kept in a readily accessible location.

II.B.3.b.3 Reporting:

(I) General Requirements

52
(a) The permittee shall comply with the reporting requirements in Section I of this
permit. In addition, the permittee shall comply with the notification requirements
specified in paragraph (a)(1) of this section and the reporting requirements specified in
paragraph (a)(2) of this section.

(1) The permittee shall submit notices to the Director in accordance with the
applicable notification requirements in 40 CFR 63.9 as specified in Table 2 of 40
CFR 63 Subpart DD.

(2) The permittee shall submit reports to the Director in accordance with the
applicable reporting requirements in 40 CFR 63.10 as specified in Table 2 of 40
CFR 63 Subpart DD.

(b) The permittee shall send a copy of each report submitted to the Director to Region 8 of
the EPA to the address given in Section I of this permit.

(II) Specific Requirements.

(a) A report shall be submitted to the Director semiannually starting 6 months after
the initial report required in paragraph (a) of 40 CFR 61.247, that includes the following
information:

(1) Process unit identification.

(2) For each month during the semiannual reporting period,

(i) Number of valves for which leaks were detected as described in paragraph
(b) of section VII of this condition.

(ii) Number of valves for which leaks were not repaired as required in
paragraph (d) section VII of this condition.

(iii) Number of pumps for which leaks were detected as described in
paragraph (b) section III of this condition.

(iv) Number of pumps for which leaks were not repaired as required in
paragraph (c) section III of this condition.

(v) The facts that explain any delay of repairs and, where appropriate, why a
process unit shutdown was technically infeasible.

(3) Dates of process unit shutdowns which occurred within the semiannual
reporting period.

(4) Revisions to items reported according to paragraph (a) of 40 CFR 61.247 if
changes have occurred since the initial report or subsequent revisions to the initial
report.

(5) The results of all performance tests and monitoring to determine compliance
with no detectable emissions and with sections X and XI of this condition
conducted within the semiannual reporting period.

53
(b) In the first report submitted as required in paragraph (a) of 40 CFR 61.247, the report
shall include a reporting schedule stating the months that semiannual reports shall be
submitted. Subsequent reports shall be submitted according to that schedule, unless a
revised schedule has been submitted in a previous semiannual report.

(c) The permittee electing to comply with the provisions of sections X and XI of this
condition shall notify the Director of the alternative standard selected 90 days before
implementing either of the provisions.

(d) An application for approval of construction or modification, 40 CFR 61.05(a) and
61.07, will not be required if-

(1) The new source complies with the standards of this condition;

(2) The new source is not part of the construction of a process unit; and

(3) In the next semiannual report required by paragraph (a) of this section, the
information in paragraph (a)(5) of 40 CFR 61.247 is reported.

Status: In compliance – A Leak Detection and Repair (LDAR) Plan, dated May 31, 2023, is in place
and is tracked with CHATEAU an electronic database. Pumps are monitored monthly and
also visually checked weekly. Valves are monitored quarterly. The company is utilizing the
skip monitoring provision and reverts back to monthly monitoring when leaks are detected.
There are no unsafe-to-monitor or difficult-to-monitor valves. The company is not using the
alternative standards listed in (X) but is using the alternative listed in (XI) by going off the
2.0 percent leak rate. Instruments (FID) are auto calibrated each day. The most recent
semi-annual 40 CFR 61 Subpart V and 40 CFR 63 Subpart DD report (LDAR), dated
December 5, 2024, was received on December 9, 2024, and deemed acceptable.

II.B.3.c Condition:

The emission from the repack room in Building E-4 shall go through the carbon adsorption
system before it is vented into the atmosphere.

[Authority granted under R307-401-8; condition originated in DAQE-AN107250026A-16].

II.B.3.c.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status.

II.B.3.c.2 Recordkeeping:

Result of monitoring shall be maintain in accordance with Provision S.1 in Section I of this
permit.

II.B.3.c.3 Reporting:

There are no additional reporting requirements except as outlined in Section I of this
permit.

Status: In compliance – Emissions from the repack room are vented through the carbon absorption
system before being vented to the atmosphere.
54
II.B.4 Conditions on Off-Site Material Containers (CNT)

II.B.4.a Condition:

40 CFR Part 61, Subpart FF

(I) Affected Wastes.

(a) Each waste which enters the permittee's facility which includes a notice from the waste
generator stating that the waste contains benzene which is required to be managed and
treated in accordance with the provisions of 40 CFR 61 Subpart FF (see 40 CFR
61.342(f)(2)), shall be managed and treated in accordance with the standards of this
condition.

(b) When the total annual benzene (TAB) quantity as determined by the procedures in (a)
of monitoring is equal to or greater than 10 Mg/yr., the permittee shall manage and treat
each waste received from chemical manufacturing plants, coke by-product recovery plants
and petroleum refineries in accordance with the standards of this condition.

(II) Container Management Standards

(a) The permittee shall meet the following standards for each container in which an
affected waste is placed or present: Container means any portable waste management unit
in which a material is stored, transported, treated, or otherwise handled. Examples of
containers are drums, barrels, tank trucks, barges, dumpsters, tank cars, dump trucks, and
ships.

(1) The permittee shall install, operate, and maintain a cover in accordance with
the following requirements:

(i) The cover and all openings (e.g., bungs, hatches, and sampling ports)
shall be designed to operate with no detectable emissions as indicated by
an instrument reading of less than 500 ppmv above background, initially
and thereafter at least once per year by the methods specified in (b) of
monitoring.

(ii) Except as provided in paragraph (a)(4) of this section, each opening
shall be maintained in a closed, sealed position (e.g., covered by a lid that
is gasketed and latched) at all times that waste is in the container except
when it is necessary to use the opening for waste loading, removal,
inspection, or sampling.

(2) When a waste is transferred into a container by pumping, the permittee shall
perform the transfer using a submerged fill pipe. The submerged fill pipe outlet
shall extend to within two fill pipe diameters of the bottom of the container while
the container is being loaded. During loading of the waste, the cover shall remain
in place and all openings shall be maintained in a closed, sealed position except
for those openings required for the submerged fill pipe, those openings required
for venting of the container to prevent physical damage or permanent deformation
of the container or cover, and any openings complying with paragraph (a)(4)
of this section.

55
(3) Treatment of a waste in a container, including aeration, thermal or other
treatment, must be performed by the permittee in a manner such that while the
waste is being treated the container meets the standards specified in paragraphs
(a)(3)(i) through (a)(3)(iii) below, except for covers and closed-vent systems that
meet the requirements in paragraph (a)(4) below.

(i) The permittee must either:

(A) Vent the container inside a total enclosure which is exhausted
through a closed-vent system to a control device in accordance
with the requirements of paragraphs (a)(3)(ii)(A) and (B) below;
or

(B) Vent the covered or closed container directly through a
closed-vent system to a control device in accordance with the
requirements of paragraphs (a)(3)(ii)(B) and (C) below.

(ii) The permittee must meet the following requirements, as applicable to
the type of air emission control equipment selected by the owner or
operator:

(A) The total enclosure must be designed and operated in
accordance with the criteria for a permanent total enclosure as
specified in section 5 of the "Procedure T-Criteria for and
Verification of a Permanent or Temporary Total Enclosure" in 40
CFR 52.741, appendix B. The enclosure may have permanent or
temporary openings to allow worker access; passage of containers
through the enclosure by conveyor or other mechanical means;
entry of permanent mechanical or electrical equipment; or direct
airflow into the enclosure. The owner or operator must perform
the verification procedure for the enclosure as specified in section
5.0 of “Procedure T-Criteria for and Verification of a Permanent
or Temporary Total Enclosure" initially when the enclosure is
first installed and, thereafter, annually. A facility that has
conducted an initial compliance demonstration and that performs
annual compliance demonstrations in accordance with the
Container Level 3 control requirements in 40 CFR 4.1086(e)(2)(i)
or 40 CFR 265.1086(e)(2)(i) is not required to make repeat
demonstrations of initial and continuous compliance for the
purposes of this condition.

(B) The closed-vent system and control device must be designed
and operated in accordance with the requirements of 40 CFR
61.349.

(C) For a container cover, the cover and all openings (e.g., doors,
hatches) must be designed to operate with no detectable
emissions as indicated by an instrument reading of less than 500
ppmv above background, initially and thereafter at least once per
year by the methods specified in 40 CFR 61.355(h).

56
(iii) Safety devices, as defined in 40 CFR 61.341, may be installed and
operated as necessary on any container, enclosure, closed-vent system, or
control device used to comply with the requirements of paragraph
(a)(3)(i) above.

(4) If the cover and closed-vent system operate such that the container is
maintained at a pressure less than atmospheric pressure, the permittee may
operate the system with an opening that is not sealed and kept closed at all times
if the following conditions are met:

(i) The purpose of the opening is to provide dilution air to reduce the
explosion hazard;

(ii) The opening is designed to operate with no detectable emissions as
indicated by an instrument reading of less than 500 ppmv above
background, as determined initially and thereafter at least once per year
by methods specified in (b) of monitoring; and

(iii) The pressure is monitored continuously to ensure that the pressure in
the container remains below atmospheric pressure.

(b) Each cover and all openings shall be visually inspected initially and quarterly
thereafter to ensure that they are closed and gasketed properly.

(c) Except as provided in section V of this condition, when a broken seal or gasket or
other problem is identified, first efforts at repair shall be made as soon as practicable, but
not later than 15 calendar days after identification.

(III) Closed Vent System and Control Device

(a) The closed-vent system and control device shall be designed and operated in
accordance with the following requirements.

(1) The closed-vent system shall:

(i) Be designed to operate with no detectable emissions as indicated by an
instrument reading of less than 500 ppmv above background, as
determined initially and thereafter at least once per year by the methods
specified in (b) of monitoring.

(ii) All gauging and sampling devices shall be gas-tight except when
gauging or sampling is taking place.

(2) The control devices shall be designed and operated in accordance with the
following conditions:

(i) The incinerator shall provide a minimum residence time of 0.5 seconds
at a minimum temperature of 760°C (1,400 °F).

(ii) The carbon adsorption systems shall recover or control the organic
emissions vented to it with an efficiency of 95 weight percent or greater.

57
(b) The closed-vent system and incinerator or carbon adsorption system shall be operated
at all times when an affected waste is placed or present in a container and the container is
vented to the incinerator or carbon adsorption system.

(c) The permittee shall demonstrate that each control device achieves the appropriate
conditions specified in paragraph (a)(2) of this section by using engineering calculations
in accordance with requirements specified in (f) of recordkeeping.

(d) The Director may request at any time the permittee demonstrate that a control device
meets the applicable conditions specified in paragraph (a)(2) of this section by
conducting a performance test using the test methods and procedures as required in 40
CFR 61.355.

(e) Each closed-vent system and control device shall be visually inspected initially and
quarterly thereafter. The visual inspection shall include inspection of ductwork and
piping and connections to covers and control devices for evidence of visible defects such
as holes in ductwork or piping and loose connections.

(f) Except as provided in section V of this condition, if visible defects are observed during
an inspection, or if other problems are identified, or if detectable emissions are measured,
a first effort to repair the closed-vent system and control device shall be made as soon as
practicable but no later than 5 calendar days after detection. Repair shall be completed
no later than 15 calendar days after the emissions are detected or the visible defect is
observed.

(IV) Treatment Standards

(a) Incinerator

(1) The permittee shall treat affected waste in affected containers in accordance
with the following requirements:

(i) The permittee shall design, install, operate, and maintain a treatment
process that destroys benzene in the waste by incinerating the waste in a
combustion unit that achieves a destruction efficiency of 99 percent or
greater for benzene.

(ii) The permittee may aggregate or mix together individual wastes to
create a combined waste for the purpose of facilitating treatment of waste
to comply with the requirements of paragraph (a)(1)(i) of this section.

(2) A treatment process is in compliance with the requirements of this condition
provided that the permittee documents that the treatment process is a hazardous
waste incinerator for which the permittee has been issued a final permit under 40
CFR part 270 and complies with the requirements of 40 CFR part 264, subpart 0.

(3) Except as specified in paragraph (a)(3)(iii) of this section, if the treatment
process has any openings (e.g., access doors, hatches, etc.), all such openings shall
be sealed (e.g., gasketed, latched, etc.) and kept closed at all times when waste is
being treated, except during inspection and maintenance.

58
(i) Each seal, access door, and all other openings shall be checked by
visual inspections initially and quarterly thereafter to ensure that no
cracks or gaps occur and that openings are closed and gasketed properly.

(ii) Except as provided in section V of this condition, when a broken seal
or gasket or other problem is identified, first efforts at repair shall be
made as soon as practicable, but not later than 15 calendar days after
identification.

(iii) If the cover and closed-vent system operate such that the treatment
process is maintained at a pressure less than atmospheric pressure, the
permittee may operate the system with an opening that is not sealed and
kept closed at all times if the following conditions are met:

(A) The purpose of the opening is to provide dilution air to reduce
the explosion hazard;

(B) The opening is designed to operate with no detectable
emissions as indicated by an instrument reading of less than 500
ppmv above background, as determined initially and thereafter at
least once per year by the methods specified in (b) of monitoring;
and,

(C) The pressure is monitored continuously to ensure that the
pressure in the treatment process remains below atmospheric
pressure.

(b) Send Offsite

(1) Rather than treating the waste onsite, the permittee may elect to transfer
affected wastes offsite to another facility where the waste is treated in accordance
with the requirements of 40 CFR 60.342(c)(1)(i). If the permittee transfers the
waste offsite, the permittee shall:

(i) Comply with the standards of this condition prior to shipment of the
waste offsite.

(ii) Include with each offsite waste shipment a notice stating that the
waste contains benzene which is required to be managed and treated in
accordance with the provisions of 40 CFR 61 Subpart FF.

(V) Delay of repair.

(a) Delay of repair will be allowed if the repair is technically impossible without a
complete or partial facility or unit shutdown.

(b) Repair of such equipment shall occur before the end of the next facility or unit
shutdown.

Authority granted under 40 CFR 61.345; condition originated in 40 CFR 61 Subpart FF]

59
II.B.4.a.1 Monitoring:

(a) The permittee shall determine the TAB quantity by the following procedure:

(1) For each waste received from a chemical manufacturing plant, coke by-product
recovery plant, or petroleum refinery having a flow-weighted annual average water content
greater than 10 percent water, on a volume basis as total water, as indicated from
information provided by the generator for the associated waste stream at the generator's
facility or is mixed with water or other wastes at the permittee's facility at any time and the
resulting mixture has an average water content greater than 10 percent, the permittee shall:

(i) Determine the waste quantity at the point where the waste enters the permittee's
facility.

(ii) Determine the flow-weighted annual average benzene concentration from
information provided by the generator for the associated waste stream at the
generator's facility.

(iii) Calculate the benzene quantity for the waste by multiplying the waste quantity
times the flow-weighted annual average benzene concentration of the waste.

(2) The TAB quantity is calculated by adding together the benzene quantity as determined
in (a)(1) above for each waste which enters the permitted source during the year.

(b) The permittee shall test equipment for compliance with no detectable emissions in accordance
with the following requirements:

(1) Monitoring shall comply with Method 21 from appendix A of 40 CFR part 60.

(2) The detection instrument shall meet the performance criteria of Method 21.

(3) The instrument shall be calibrated before use on each day of its use by the procedures
specified in Method 21.

(4) Calibration gases shall be:

(i) Zero air (less than 10 ppm of hydrocarbon in air); and

(ii) A mixture of methane or n-hexane and air at a concentration of approximately,
but less than, 10,000 ppm methane or n-hexane.

(5) The background level shall be determined as set forth in Method 21.

(6) The instrument probe shall be traversed around all potential leak interfaces as close as
possible to the interface as described in Method 21.

(7) The arithmetic difference between the maximum concentration indicated by the
instrument and the background level is compared to 500 ppm for determining compliance.

(c) For each system using an emission control that is maintained at a pressure less than atmospheric
pressure with openings to provide dilution air, the permittee shall install, calibrate, maintain, and
operate according to the manufacturer's specifications a device equipped with a continuous recorder
to monitor the pressure in the unit to ensure that it is less than atmospheric pressure.
60
(d) The permittee shall install, calibrate, maintain, and operate according to the manufacturer's
specifications a device to continuously monitor the control device operation as specified in the
following paragraphs. The permittee shall inspect at least once each operating day the data recorded
by the monitoring equipment (e.g., temperature monitor or flow indicator) to ensure that the control
device is operating properly.

(1) For the incinerator, a temperature-monitoring device equipped with a continuous
recorder. The device shall have an accuracy of ±1 percent of the temperature being
monitored in °C or ±0.5°C, whichever is greater. The temperature sensor shall be installed
at a representative location in the combustion chamber.

(e) The permittee shall replace the carbon in the carbon adsorption systems with fresh carbon at a
regular predetermined time interval that is less than the carbon replacement interval that is
determined by the maximum design flow rate and either the organic concentration or the benzene
concentration in the gas stream vented to the carbon adsorption system.

II.B.4.a.2 Recordkeeping:

(a) The permittee shall comply with the recordkeeping requirements of section I.S.1 of this permit.
In addition, each record shall be maintained in a readily accessible location at the facility site for a
period not less than five years from the date the information is recorded unless otherwise specified.

(b) The permittee shall maintain records that identify each waste received from chemical
manufacturing plants, coke by product recovery plants, and petroleum refineries, and indicate
whether or not the waste is controlled for benzene emissions in accordance with this condition. In
addition, the permittee shall maintain the following records. For each waste received from
chemical manufacturing plants, coke by product recovery plants, and petroleum refineries not
controlled for benzene emissions in accordance with this condition, the records shall include all
test results, measurements, calculations, and other documentation used to determine the following
information for the waste including: waste identification, water content, whether or not the waste is
a process wastewater stream, waste quantity, range of benzene concentrations for the
associated waste stream at the generator's facility, annual average flow-weighted benzene
concentration, and benzene quantity.

(c) The permittee transferring waste off-site to another facility for treatment in accordance with (b)
of section IV of this condition shall maintain documentation for each offsite waste shipment that
includes the following information: Date waste is shipped offsite, quantity of waste shipped offsite,
name and address of the facility receiving the waste, and a copy of the notice sent with the waste
shipment.

(d) The permittee shall maintain engineering design documentation for all control equipment
required by this condition that is installed on the containers. The documentation shall be retained
for the life of the control equipment.

(e) The permittee shall maintain the following records for the treatment unit. The documentation
shall be retained for the life of the unit. A statement signed and dated by the permittee certifying
that the unit is permitted as a 40 CFR part 264 Subpart O incinerator.

(f) For the closed-vent systems and control devices, the permittee shall maintain the following
records. The documentation shall be retained for the life of the control devices.

(1) A statement signed and dated by the permittee certifying that the closed-vent systems
and control devices are designed to operate at the documented performance level when a
61
container containing an affected waste is vented to the control device is or would be
operating at the highest load or capacity expected to occur.

(2) A design analysis for the control device that includes for example:

(i)Specifications, drawings, schematics, and piping and instrumentation diagrams
prepared by the permittee, or the control device manufacturer or vendor that
describe the control device design based on acceptable engineering texts. The
design analysis shall address the following vent stream characteristics and control
device operating parameters:

(A) For the incinerator, the design analysis shall consider the vent stream
composition, constituent concentrations, and flow rate. The design analysis
shall also establish the design minimum and average temperature in the
combustion zone and the combustion zone residence time

(B) For the carbon adsorption systems, the design analysis shall consider
the vent stream composition, constituent concentration, flow rate, relative
humidity, and temperature. The design analysis shall also establish the
design exhaust vent stream organic compound concentration level or the
design exhaust vent stream benzene concentration level, capacity of carbon
bed, type and working capacity of activated carbon used for carbon bed,
and design carbon replacement interval based on the total carbon working
capacity of the control device and source operating schedule.

(g) The permittee shall maintain a record for each visual inspection that identifies a problem (such
as a broken seal, gap or other problem) which could result in benzene emissions. The record shall
include the date of the inspection, waste management unit and control equipment location where
the problem is identified, a description of the problem, a description of the corrective action taken,
and the date the corrective action was completed.

(h) The permittee shall maintain a record for each test of no detectable emissions. The record shall
include the following information: date the test is performed, background level measured during
test, and maximum concentration indicated by the instrument reading measured for each potential
leak interface. If detectable emissions are measured at a leak interface, then the record shall also
include the waste management unit, control equipment, and leak interface location where
detectable emissions were measured, a description of the problem, a description of the corrective
action taken, and the date the corrective action was completed.

(i) The permittee shall maintain documentation that includes the following information regarding
the treatment unit operation:

(1) Dates of startup and shutdown of the unit.

(2) Periods when the unit is not operated as designed.

(j) For each control device, the permittee shall maintain documentation that includes the following
information regarding the control device operation:

(1) Dates of startup and shutdown of the closed-vent system and control device.

(2) A description of the operating parameter (or parameters) to be monitored to
ensure that the control device will be operated in conformance with these
62
standards and the control device's design specifications and an explanation of the
criteria used for selection of that parameter (or parameters). This documentation
shall be kept for the life of the control device.

(3) Periods when the closed-vent system and control device are not operated as
designed.

(4) The permittee shall maintain continuous records of the temperature of the gas
stream in the combustion zone of the incinerator and records of all 3-hour periods
of operation during which the average temperature of the gas stream in the
combustion zone is more than 28°C (50 °F) below the design combustion zone
temperature.

(5) The permittee shall record each occurrence when the vent stream continues to
flow through the control device beyond the predetermined carbon bed regeneration
time.

(6) For the carbon absorbers, the permittee shall maintain records of dates and times when
the control device is monitored, and shall record the date and time that the existing carbon
in the control device is replaced with fresh carbon.

(k) If a system is used for emission control that is maintained at a pressure less than atmospheric
pressure with openings to provide dilution air, the permittee shall maintain records of the
monitoring device and records of all periods during which the pressure in the unit is operated at a
pressure that is equal to or greater than atmospheric pressure.

(l) If a total enclosure is used to comply with the control requirements for containers, then the
permittee must keep records (1) and (2) listed below. The permittee may use records as required in
40 CFR 264.1089(d)(1) or 40 CFR 265.1090(d)(1) to meet the recordkeeping requirement in
paragraph (1) below. The permittee must make the records of each verification of a total enclosure
available for inspection upon request.

(1) Records of the most recent set of calculations and measurements performed to verify
that the enclosure meets the criteria of a permanent total enclosure as specified in
"Procedure T-Criteria for and Verification of a Permanent or Temporary Total Enclosure"
in 40 CFR 52.741, appendix B;

(2) Records required for a closed-vent system and control device according to the
requirements in paragraphs (d), (f) and (j) above

II.B.4.a.3 Reporting:

(a) The permittee shall comply with the reporting requirements in Section I of this Permit. In
addition, the permittee shall submit a report that includes the following information according to
the schedule provided below.

(1) Total annual benzene quantity from waste received from applicable waste generators
determined in accordance with the procedures in (a) of monitoring.

(2) A table identifying each container received from applicable waste generators and
whether or not the container will be controlled for benzene emissions in accordance with
the requirements of this condition.

63
(3) For each container received from an applicable waste generator identified as not being
controlled for benzene emissions in accordance with the requirements of this condition the
following information shall be added to the table:

(i) Whether or not the water content of the waste is greater than 10 percent;

(ii) Whether or not the waste is a process wastewater stream, product tank
drawdown, or landfill leachate;

(iii) Quantity for the waste;

(iv) Benzene concentrations for the waste;

(v) Average benzene concentration for the waste; and

(vi) Benzene quantity for the waste.

(4) The permittee only needs to list in the report those wastes received from applicable
waste generators that contact materials containing benzene. The report does not need to
include a description of the controls to be installed to comply with the standard or other
information required in 40 CFR 61.10(a).

(b) If the total annual benzene quantity from containers received from applicable waste generators
is less than 1 Mg/yr. (1.1 ton/yr.), then the permittee shall submit to the Director a report that
updates the information listed in paragraphs (a)(1) through (a)(3) of this section whenever there is
a change in the wastes received that could cause the total annual benzene quantity from wastes
received from applicable waste generators to increase to 1 Mg/yr. (1.1 ton/yr.) or more.

(c) If the total annual benzene quantity from wastes received from applicable waste generators is
less than 10 Mg/yr. (11 ton/yr.) but is equal to or greater than 1 Mg/yr. (1.1 ton/yr.) then the
permittee shall submit to the Director a report that updates the information listed in paragraphs
(a)(1) through (a)(3) of this section. The report shall be submitted annually and whenever there is a
change in the wastes received that could cause the total annual benzene quantity from wastes
received from applicable waste generators to increase to 10 Mg/yr. (11 ton/yr.) or more. If the
information in the annual report required by paragraphs (a)(1) through (a)(3) of this section is not
changed in the following year, the permittee may submit a statement to that effect.

(d) The permittee shall submit to the Director the following reports:

(1) Prior to the date the total annual benzene quantity from waste received from applicable
waste generators is equal to or greater than 10 Mg/yr., a certification that the equipment
necessary to comply with these standards has been installed and that the required initial
inspections or tests have been carried out in accordance with this condition.

(2) Beginning on the date that the equipment necessary to comply with these standards has
been certified in accordance with paragraph (d)(1) of this section, the permittee shall
submit annually to the Director a report that updates the information listed in paragraphs
(a)(1) through (a)(3) of this section. If the information in the annual report required by
paragraphs (a)(1) through (a)(3) of this section is not changed in the following year, the
permittee may submit a statement to that effect.

(3) Beginning 3 months after the date that the equipment necessary to comply with these
standards has been certified in accordance with paragraph (d)(1) of this section, the
64
permittee shall submit quarterly to the Director a certification that all of the required
inspections have been carried out in accordance with the requirements of this condition.

(4) Beginning 3 months after the date that the equipment necessary to comply with these
standards has been certified in accordance with paragraph (d)(1) of this section, the
permittee shall submit a report quarterly to the Director that includes:

(i) Each period of operation monitored during which any of the following
conditions occur, as applicable to the control device:

(A) Each 3-hour period of operation during which the average temperature
of the gas stream in the combustion zone of the incinerator, as measured
by the temperature monitoring device, is more than 28°C (50 °F) below the
design combustion zone temperature.

(B) Each occurrence when the carbon in a carbon absorber system is not
replaced at the predetermined interval.

(ii) For a cover and closed-vent system monitored in accordance with (c) of
monitoring, the permittee shall submit a report quarterly to the Director that
identifies any period in which the pressure in the unit is equal to or greater than
atmospheric pressure.

(5) Beginning one year after the date that the equipment necessary to comply with these
standards has been certified in accordance with paragraph (d)(1) of this section, the
permittee shall submit annually to the Director a report that summarizes all inspections
during which detectable emissions are measured or a problem (such as a broken seal, gap
or other problem) that could result in benzene emissions is identified, including
information about the repairs or corrective action taken.

(e) Reserved.

(f) The permittee shall send a copy of each report submitted to the Director, to Region 8 of the
EPA, to the address given in Section I of this permit.

Status: In compliance - Waste is coded with a profile showing the contents. Standard profile
information forms have a question slot asking the waste generator about benzene content.

Portable containers are kept closed. Repacking and decanting are performed in the repack
room that captures emissions and vents them to either the incinerator or the carbon filter
system. Submerged filling is used when waste is pumped into tankers. Treatment of waste in
a container is vented to a kiln during normal operation. When the kiln is offline, tank farm 1
is vented to two carbon canisters and the bulk solids tank to a carbon bed.

The annual Procedure Off-Line Total Enclosure Test was performed on March 7, 2025. The
Procedure On-Line Total Enclosure Test was performed on March 21, 2025. The results of
the tests were promptly (within 7 days) submitted to the Division of Waste Management and
Radiation Control.

Covers and openings are inspected quarterly in the LDAR program. Broken seals and
gaskets are repaired within 15 calendar days.

65
Incinerator residence time and temperature requirements are entered into an electronic
system, and alarms are set to notify operators in the event of excursion.

Daily walkthrough inspections of the closed-vent system are conducted and inspection
records are kept.

The facility is designed to achieve a benzene destruction efficiency of at least 99.99 percent.
Benzene destruction efficiency is verified during the Subpart EEE CPT.

The 2024 Total Annual Benzene (TAB) NESHAP Report, dated March 17, 2025, was
received on March 21, 2025, by the DAQ and deemed acceptable. All Quarterly Benzene
NESHAP reports for calendar year 2024 have been submitted. The First Quarter Benzene
2025 report will be submitted in April of 2025.

II.B.4.b Condition:

40 CFR Part 63 Subpart DD

(I) Affected Containers

(a) For each container, the permittee shall meet the requirements in either paragraph (2), or
(3) of this section except for those containers subject to 40 CFR 61 Subpart FF (see
previous condition) and those containers that do not contain off-site materials as specified
in (1).

Off-site material stream means an off-site material produced or generated by a particular
process or source such that the composition and form of the material comprising the stream
remain consistent. An off-site material stream may be delivered, transferred, or otherwise
moved to the plant site in a continuous flow of material (e.g., wastewater flowing through a
pipeline) or in a series of discrete batches of material (e.g., a truckload of drums all
containing the same off-site material or multiple bulk truckloads of an off-site material
produced by the same process).

Container means a portable unit used to hold material. Examples of containers include but
are not limited to drums, dumpsters, roll-off boxes, bulk cargo containers commonly
known as "portable tanks" or "totes", cargo tank trucks, and tank rail cars.

(1) The following materials are not off-site materials:

(i) Household waste as defined in 40 CFR 258.2.

(ii) Waste that is generated as a result of implementing remedial activities
required under the Resource Conservation and Recovery Act (RCRA)
corrective action authorities (RCRA sections 3004(u), 3004(v), or
3008(h)), Comprehensive Environmental Response, Compensation, and
Liability Act (CERLCLA) authorities, or similar Federal or State
authorities.

(iii) Waste containing HAP that is generated by residential households
(e.g., old paint, home garden pesticides) and subsequently is collected as a
community service by government agencies, businesses, or other
organizations for the purpose of promoting the proper disposal of this
66
waste.

(iv) Hazardous waste that is stored for 10 days or less at a transfer facility
in compliance with the provisions of 40 CFR 263.12.

(2) Control air emissions from the container in accordance with the applicable
standards specified in sections II, III, IV and V of this condition.

(3) Determine before placing off-site material in the container that the average
VOHAP concentration of the off-site material is less than 500 parts per million by
weight (ppmw) at the point-of-delivery. The permittee shall perform an initial
determination of the average VOHAP concentration of the off-site material using
the procedures specified in section (a) of monitoring. This initial determination
shall be performed before the first time any portion of the off-site material stream
is placed in the container. Thereafter, the permittee shall review and update, as
necessary, this determination at least once every calendar year following the date
of the initial determination for the off-site material stream.

(b) A container is exempted from the requirements in paragraph (a) of this section if the
off-site material placed in the unit is a hazardous waste that meets the conditions specified
in either paragraph (1) or (2).

(1) The hazardous waste meets the numerical organic concentration limits,
applicable to the hazardous waste, as specified in 40 CFR part 268-Land Disposal
Restrictions, listed in the table, "Treatment Standards for Hazardous Waste" in 40
CFR 268.40.

(2) The organic hazardous constituents in the hazardous waste have been treated by
the treatment technology established by the EPA for the hazardous waste in 40
CFR 268.42(a), or have been removed or destroyed by an equivalent method of
treatment approved by the EPA under 40 CFR 268.42(b).

(II) Standards: Containers 0.1 to 0.46 m3 and larger containers not in light material service.

(a) For a container having a design capacity greater than 0.1 m3 and less than or equal to
0.46 m3 and for containers larger than 0.46 m3 not in light material service, the permittee
shall control air emissions using Container Level 1 controls as specified below.

Light-material service means the container is used to manage an off-site material for which
both of the following conditions apply: the vapor pressure of one or more of the organic
constituents in the off-site material is greater than 0.3 kilopascals (kPa) at 20 °C; and the
total concentration of the pure organic constituents having a vapor pressure greater than 0.3
kPa at 20 °C is equal to or greater than 20 percent by weight.

(b) A container using Container Level 1 controls is one of the following:

(1) A container that meets the applicable U.S. Department of Transportation
(DOT) regulations on packaging hazardous materials for transportation as specified
in section (e).

(2) A container equipped with a cover and closure devices that form a continuous
barrier over the container openings such that when the cover and closure devices
are secured in the closed position there are no visible holes, gaps, or other open
67
spaces into the interior of the container. The cover may be a separate cover
installed on the container (e.g., a lid on a drum, a suitably secured tarp on a roll-off
box) or may be an integral part of the container structural design (e.g., a bulk cargo
container equipped with a screw-type cap).

(3) An open-top container in which an organic vapor-suppressing barrier is placed
on or over the regulated-material in the container such that no regulated-material is
exposed to the atmosphere. One example of such a barrier is application of a
suitable organic-vapor suppressing foam.

(c) A container used to meet the requirements of either paragraph (b)(2) or (b)(3) of this
section shall be equipped with covers and closure devices, as applicable to the container,
that are composed of suitable materials to minimize exposure of the regulated-material to
the atmosphere and to maintain the equipment integrity for as long as it is in service.
Factors to be considered when selecting the materials for and designing the cover and
closure devices shall include: organic vapor permeability, the effects of contact with the
material or its vapor managed in the container; the effects of outdoor exposure to wind,
moisture, and sunlight; and the operating practices used for container on which the cover is
installed.

(d) Whenever a regulated-material is in a container using Container Level 1 controls, the
Permittee shall install all covers and closure devices for the container, and secure and
maintain each closure device in the closed position except as follows:

(1) Opening of a closure device or cover is allowed for the purpose of adding
material to the container as follows:

(i) In the case when the container is filled to the intended final level in one
continuous operation, the permittee shall promptly secure the closure
devices in the closed position and install the covers, as applicable to the
container, upon conclusion of the filling operation.

(ii) In the case when discrete quantities or batches of material
intermittently are added to the container over a period of time, the
permittee shall promptly secure the closure devices in the closed position
and install covers, as applicable to the container, upon either: the container
being filled to the intended final level; the completion of a batch loading
after which no additional material will be added to the container within 15
minutes; the person performing the loading operation leaves the immediate
vicinity of the container; or the shutdown of the process generating the
material being added to the container, whichever condition occurs first.

(2) Opening of a closure device or cover is allowed for the purpose of removing
material from the container as follows:

(i) For the purpose of meeting the requirements of this section, an empty
container as defined in this condition may be open to the atmosphere at
any time (e.g., covers and closure devices are not required to be secured in
the closed position on an empty container). Empty container means a
container for which either of the following conditions exists: the container
meets the conditions for an empty container specified in 40 CFR 261.7(b);
or all regulated-material has been removed from the container except for
68
any regulated-material that remains on the interior surfaces of the
container as clingage or in pools on the container bottom due to
irregularities in the container.

(ii) In the case when discrete quantities or batches of material are removed
from the container but the container does not meet the conditions to be an
empty container as defined in this condition, the permittee shall promptly
secure the closure devices in the closed position and install covers, as
applicable to the container, upon the completion of a batch removal after
which no additional material will be removed from the container within 15
minutes, or the person performing the unloading operation leaves the
immediate vicinity of the container, whichever condition occurs first.

(3) Opening of a closure device or cover is allowed when access inside the
container is needed to perform routine activities other than transfer of regulated-
material. Examples of such activities include those times when a worker needs to
open a port to measure the depth of or sample the material in the container, or
when a worker needs to open a manhole hatch to access equipment inside the
container. Following completion of the activity, the permittee shall promptly
secure the closure device in the closed position or reinstall the cover, as applicable
to the container.

(4) Opening of a spring-loaded pressure-vacuum relief valve, conservation vent, or
similar type of pressure relief device which vents to the atmosphere is allowed
during normal operations for the purpose of maintaining the container internal
pressure in accordance with the container design specifications. The device shall be
designed to operate with no detectable organic emissions when the device is
secured in the closed position. The settings at which the device opens shall be
established such that the device remains in the closed position whenever the
container internal pressure is within the internal pressure operating range
determined by the permittee based on container manufacturer recommendations,
applicable regulations, fire protection and prevention codes, standard engineering
codes and practices, or other requirements for the safe handling of flammable,
ignitable, explosive, reactive, or hazardous materials. Examples of normal
operating conditions that may require these devices to open are during those times
when the container internal pressure exceeds the internal pressure operating range
for the container as a result of loading operations or diurnal ambient temperature
fluctuations.

(5) Opening of a safety device, as defined in this condition, is allowed at any time
conditions require it to do so to avoid an unsafe condition. Safety device means a
closure device such as a pressure relief valve, frangible disc, fusible plug, or any
other type of device which functions to prevent physical damage or permanent
deformation to equipment by venting gases or vapors during unsafe conditions
resulting from an unplanned, accidental, or emergency event. For the purpose of
this condition, a safety device is not used for routine venting of gases or vapors
from the vapor headspace underneath a cover such as during filling of the unit or to
adjust the pressure in this vapor headspace in response to normal daily diurnal
ambient temperature fluctuations. A safety device is designed to remain in a closed
position during normal operations and open only when the internal pressure, or
another relevant parameter, exceeds the device threshold setting applicable to the
equipment as determined by the permittee based on manufacturer
recommendations, applicable regulations, fire protection and prevention codes,
69
standard engineering codes and practices, or other requirements for the safe
handling of flammable, combustible, explosive, reactive, or hazardous materials.

(e) For the purpose of compliance with paragraph (b)(1) of this section, containers shall be
used that meet the applicable U.S. DOT regulations on packaging hazardous materials for
transportation as follows:

(1) The container meets the applicable requirements specified in 49 CFR part 178-
Specifications for Packagings or 49 CFR part 179-Specifications for Tank Cars.

(2) Regulated-material is managed in the container in accordance with the
applicable requirements specified in 49 CFR part 107 subpart B-Exemptions; 49
CFR part 172-Hazardous Materials Table, Special Provisions, Hazardous Materials
Communications, Emergency Response Information, and Training Requirements;
49 CFR part 173-Shippers-General Requirements for Shipments and Packaging;
and 49 CFR part 180-Continuing Qualification and Maintenance of Packagings.

(3) For the purpose of complying with this condition, no exceptions to the 49 CFR
part 178 or part 179 regulations are allowed except as provided for in paragraph (4)
of this section.

(4) For a lab pack that is managed in accordance with the requirements of 49 CFR
part 178 for the purpose of complying with this condition, the permittee may
comply with the exceptions for those packagings specified in 49 CFR 173.12(b).

(III) Standards: Containers Greater than 0.46 m3 in Light Material Service.

(a) For a container having a design capacity greater than 0.46 m3 and the container is in
light-material service, the permittee shall control air emissions from the container using
Container Level 2 controls as specified below.

(b) A container using Container Level 2 controls is one of the following:

(1) A container that meets the applicable U.S. Department of Transportation
(DOT) regulations on packaging hazardous materials for transportation as specified
in section (e).

(2) A container that has been demonstrated to operate with no detectable organic
emissions as defined in this condition. No detectable organic emissions means no
escape of organics to the atmosphere as determined using the procedure specified
in section (b) of monitoring.

(3) A container that has been demonstrated within the preceding 12 months to be
vapor-tight by using Method 27 in Appendix A of 40 CFR part 60 in accordance
with the procedure specified in section (c) of monitoring.

(c) Transfer of regulated-material in to or out of a container using Container Level 2
controls shall be conducted in such a manner as to minimize exposure of the regulated-
material to the atmosphere, to the extent practical, considering the physical properties of
the regulated-material and good engineering and safety practices for handling flammable,
ignitable, explosive, or other hazardous materials. Examples of container loading
procedures that meet the requirements of this paragraph include using any one of the
following: a submerged-fill pipe or other submerged-fill method to load liquids into the
70
container; a vapor-balancing system or a vapor-recovery system to collect and control the
vapors displaced from the container during filling operations; or a fitted opening in the top
of a container through which the regulated-material is filled, with subsequent purging of
the transfer line before removing it from the container opening.

(d) Whenever a regulated-material is in a container using Container Level 2 controls, the
Permittee shall install all covers and closure devices for the container, and secure and
maintain each closure device in the closed position except as follows:

(1) Opening of a closure device or cover is allowed for the purpose of adding
material to the container as follows:

(i) In the case when the container is filled to the intended final level in one
continuous operation, the permittee shall promptly secure the closure
devices in the closed position and install the covers, as applicable to the
container, upon conclusion of the filling operation.

(ii) In the case when discrete quantities or batches of material
intermittently are added to the container over a period of time, the
permittee shall promptly secure the closure devices in the closed position
and install covers, as applicable to the container, upon either the container
being filled to the intended final level, the completion of a batch loading
after which no additional material will be added to the container within 15
minutes, the person performing the loading operation leaves the immediate
vicinity of the container, or the shutdown of the process generating the
material being added to the container, whichever condition occurs first.

(2) Opening of a closure device or cover is allowed for the purpose of removing
material from the container as follows:

(i) For the purpose of meeting the requirements of this section, an empty
container as defined in this condition may be open to the atmosphere at
any time (e.g., covers and closure devices are not required to be secured in
the closed position on an empty container).

(ii)I n the case when discrete quantities or batches of material are removed
from the container but the container does not meet the conditions to be an
empty container as defined in this condition, the permittee shall promptly
secure the closure devices in the closed position and install covers, as
applicable to the container, upon the completion of a batch removal after
which no additional material will be removed from the container within 15
minutes or the person performing the unloading operation leaves the
immediate vicinity of the container, whichever condition occurs first.

(3) Opening of a closure device or cover is allowed when access inside the
container is needed to perform routine activities other than transfer of regulated-
material. Examples of such activities include those times when a worker needs to
open a port to measure the depth of or sample the material in the container, or
when a worker needs to open a manhole hatch to access equipment inside the
container. Following completion of the activity, the permittee shall promptly
secure the closure device in the closed position or reinstall the cover, as applicable
to the container.

71
(4) Opening of a spring-loaded pressure-vacuum relief valve, conservation vent, or
similar type of pressure relief device which vents to the atmosphere is allowed
during normal operations for the purpose of maintaining the container internal
pressure in accordance with the container design specifications. The device shall be
designed to operate with no detectable organic emissions when the device is
secured in the closed position. The settings at which the device opens shall be
established such that the device remains in the closed position whenever the
container internal pressure is within the internal pressure operating range
determined by the permittee based on container manufacturer recommendations,
applicable regulations, fire protection and prevention codes, standard engineering
codes and practices, or other requirements for the safe handling of flammable,
combustible, explosive, reactive, or hazardous materials. Examples of normal
operating conditions that may require these devices to open are during those times
when the container internal pressure exceeds the internal pressure operating range
for the container as a result of loading operations or diurnal ambient temperature
fluctuations.

(5) Opening of a safety device, as defined in this condition, is allowed at any time
conditions require it to do so to avoid an unsafe condition.

(e) For the purpose of compliance with paragraph (b)(1) of this section, containers shall be
used that meet the applicable U.S. DOT regulations on packaging hazardous materials for
transportation as follows:

(1) The container meets the applicable requirements specified in 49 CFR part 178-
Specifications for Packagings or 49 CFR part 179-Specifications for Tank Cars.

(2) Regulated-material is managed in the container in accordance with the
applicable requirements specified in 49 CFR part 107 subpart B- Exemptions; 49
CFR part 172- Hazardous Materials Table, Special Provisions, Hazardous
Materials Communications, Emergency Response Information, and Training
Requirements; 49 CFR part 173- Shippers-General Requirements for Shipments
and Packaging; and 49 CFR part 180-Continuing Qualification and Maintenance of
Packagings.

(3) For the purpose of complying with this condition, no exceptions to the 49 CFR
part 178 or part 179 regulations are allowed except as provided for in paragraph (4)
of this section.

(4) For a lab pack that is managed in accordance with the requirements of 49 CFR
part 178 for the purpose of complying with this condition, the permittee may
comply with the exceptions for those packagings specified in 49 CFR 173.12(b).

(IV) Standards: Containers Greater than 0.1 m3 used for Treatment of Off-Site Material.

(a) For a container having a design capacity greater than 0.1 m3 and is used for treatment
of an off-site material by a waste stabilization process, the permittee shall control air
emissions from the container at those times during the process when the off-site material in
the container is exposed to the atmosphere using Container Level 3 controls as specified
below. Waste stabilization process means any physical or chemical process used to either
reduce the mobility of hazardous constituents in a waste or eliminate free liquids as
determined by Test Method 9095-Paint Filter Liquids Test in "Test Methods for Evaluating
Solid Waste, Physical/Chemical Methods," EPA Publication No. SW-846, Third Edition,
72
September 1986, as amended by Update I, November 15, 1992. (As an alternative, the
permittee may use any more recent, updated version of Method 9095 approved by the
EPA.) A waste stabilization process includes mixing the waste with binders or other
materials and curing the resulting waste and binder mixture. Other synonymous terms used
to refer to this process are "waste fixation" or "waste solidification." A waste stabilization
process does not include the adding of absorbent materials to the surface of a waste,
without mixing, agitation, or subsequent curing, to absorb free liquid.

(b) A container using Container Level 3 controls is a container that is vented inside an
enclosure which is exhausted through a closed-vent system to a control device in
accordance with the requirements of paragraphs (1) and (2) of section (c).

(c) The permittee shall meet the following requirements as applicable to the type of air
emission control equipment selected by the permittee:

(1) The enclosure shall be designed and operated in accordance with the criteria for
a permanent total enclosure as specified in "Procedure T-Criteria for and
Verification of a Permanent or Temporary Total Enclosure" under 40 CFR 52.741,
Appendix B. The enclosure may have permanent or temporary openings to allow
worker access; passage of containers through the enclosure by conveyor or other
mechanical means; entry of permanent mechanical or electrical equipment; or to
direct airflow into the enclosure. The permittee shall perform the verification
procedure for the enclosure as specified in Section 5.0 to "Procedure T-Criteria for
and Verification of a Permanent or Temporary Total Enclosure" initially when the
enclosure is first installed and, thereafter, annually.

(2) The closed-vent system and control device shall be designed and operated in
accordance with the requirements of Section V of this condition.

(d) Safety devices may be installed and operated as necessary on any container, enclosure,
closed-vent system, or control device used to comply with this section.

(V) Standards: Container Level 3 Closed-Vent System and Control Devices

(a) Closed-vent system and requirements.

(1) The vent stream required to be controlled shall be conveyed to the control
device by a closed-vent system that is designed to operate with no detectable
organic emissions using the procedure specified in section (b) of monitoring.

(b) Carbon adsorption control device requirements.

(1) The carbon adsorption system shall recover 95 percent or more, on a weight-
basis, of the total organic compounds (TOC), less methane and ethane, contained
in the vent stream entering the carbon adsorption system.

(2) The permittee shall demonstrate that the carbon adsorption system achieves the
performance requirements by a design analysis. The design analysis shall address
the vent stream composition, constituent concentrations, flow rate, relative
humidity, and temperature and shall establish the design exhaust vent stream
organic compound concentration, carbon bed capacity, activated carbon type and
working capacity, and design carbon replacement interval based on the total carbon
working capacity of the control device and emission point operating schedule.
73

(3) The spent carbon removed from the carbon adsorption system shall be burned
in a hazardous waste incinerator for which the permittee has been issued a final
permit under 40 CFR part 270 that implements the requirements of 40 CFR part
264, subpart O.

(4) The permittee shall replace either the existing carbon canister with a new
carbon canister or replace the existing carbon in the control device with fresh
carbon at a regular, predetermined time interval that is less than the design carbon
replacement interval established as a requirement of (2) of this section.

(c) Vapor incinerator control device requirements.

(1) The permittee shall maintain the conditions in the vapor incinerator combustion
chamber at a residence time of 0.5 seconds or longer and at a temperature of 760oC
or higher.

(2) The permittee shall demonstrate that the vapor incinerator achieves the
performance requirements in paragraph (1) of this section by a design analysis. The
design analysis shall address the vent stream composition, constituent
concentrations, and flow rate and shall establish the design minimum and average
temperatures in the combustion chamber and the combustion chamber residence
time.

(3) The permittee shall monitor the operation of the vapor incinerator in
accordance with the requirements of section (f) of monitoring using a continuous
parameter monitoring system to measure and record the daily average temperature
of the exhaust gases from the control device. The accuracy of the temperature
monitoring device shall be ±1 percent of the temperature being measured,
expressed in degrees Celsius of ±0.5oC, whichever is greater. [Authority granted
under 40 CFR 63.688; condition originated in 40 CFR 63 Subpart DD].

II.B.4.b.1 Monitoring:

(a) Testing methods and procedures to determine average VOHAP concentration of an off-
site material stream at the point-of-delivery.

(1) The average VOHAP concentration of an off-site material at the point-of
delivery shall be determined using either direct measurement as specified in
paragraph (a)(2) of this section or by knowledge as specified in paragraph (a)(3) of
this section.

(2) Direct measurement to determine VOHAP concentration.

(i) Sampling. Samples of the off-site material stream shall be collected
from the container (Note: all waste is delivered in containers) used to
deliver off-site material stream to the plant site in a manner such that
volatilization of organics contained in the sample is minimized and an
adequately representative sample is collected and maintained for analysis
by the selected method.

(A) The averaging period to be used for determining the average
VOHAP concentration for the off-site material stream on a mass-
74
weighted average basis shall be designated and recorded. The
averaging period can represent any time interval that the permittee
determines is appropriate for the off-site material stream but shall
not exceed 1 year.

(B) A sufficient number of samples, but no less than four samples,
shall be collected to represent the complete range of HAP
compositions and HAP quantities that occur in the off-site material
stream during the entire averaging period due to normal variations
in the operating conditions for the source or process generating the
off-site material stream. Examples of such normal variations are
seasonal variations in off-site material quantity or fluctuations in
ambient temperature.

(C) All samples shall be collected and handled in accordance with
written procedures prepared by the permittee and documented in a
site sampling plan. This plan shall describe the procedure by
which representative samples of the off-site material stream are
collected such that a minimum loss of organics occurs throughout
the sample collection and handling process and by which sample
integrity is maintained. A copy of the written sampling plan shall
be maintained on-site in the plant site operating records. An
example of an acceptable sampling plan includes a plan
incorporating sample collection and handling procedures in
accordance with the requirements specified in "Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods," EPA
Publication No. SW-846 or Method 25D in 40 CFR part 60,
appendix A.

(ii) Analysis. Each collected sample shall be prepared and analyzed in
accordance with one of the following methods as applicable to the sampled
off-site material for the purpose of measuring the HAP listed in Table 1 of
40 CFR 63 Subpart DD:

(A) Method 305 in 40 CFR part 63, appendix A.

(B) Method 25D in 40 CFR part 60, appendix A.

(C) Method 624 in 40 CFR part 136, appendix A. If this method is
used to analyze one or more compounds that are not on the
method's published list of approved compounds, the Alternative
Test Procedure specified in 40 CFR 136.4 and 40 CFR 136.5 shall
be followed.

(D) Method 625 in 40 CFR part 136, appendix A. For the purpose
of using this method to comply with this condition, the permittee
shall perform corrections to these compounds based on the
"accuracy as recovery" using the factors in Table 7 of the method.
If this method is used to analyze one or more compounds that are
not on the method's published list of approved compounds, the
Alternative Test Procedure specified in 40 CFR 136.4 and 40 CFR
136.5 shall be followed.

75
(E) Method 1624 in 40 CFR part 136, appendix A.

(F) Method 1625 in 40 CFR part 136, appendix A.

(G) Method 8260 in "Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods," EPA Publication No. SW-846,
Third Edition, September 1986, as amended by Update I,
November 15, 1992. As an alternative, the permittee may use any
more recent, updated version of Method 8260 approved by the
EPA. For the purpose of using Method 8260 to comply with this
condition, the permittee shall maintain a formal quality assurance
program consistent with section 8 of Method 8260, and this
program shall include the following elements related to measuring
the concentrations of volatile compounds:

1. Documentation of site-specific procedures to minimize the
loss of compounds due to volatilization, biodegradation,
reaction, or sorption during the sample collection, storage, and
preparation steps.

2. Documentation of specific quality assurance procedures
followed during sampling, sample preparation, sample
introduction, and analysis.

3. Measurement of the average accuracy and precision of the
specific procedures, including field duplicates and field
spiking of the off-site material source before or during
sampling with compounds having similar chemical
characteristics to the target analytes.

(H) Method 8270 in "Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods," EPA Publication No. SW-846,
Third Edition, September 1986, as amended by Update I,
November 15, 1992. As an alternative, the permittee may use any
more recent, updated version of Method 8270 approved by the
EPA. For the purpose of using Method 8270 to comply with this
condition, the permittee shall maintain a formal quality assurance
program consistent with Method 8270, and this program shall
include the following elements related to measuring the
concentrations of volatile compounds:

1. Documentation of site-specific procedures to minimize the
loss of compounds due to volatilization, biodegradation,
reaction, or sorption during the sample collection, storage, and
preparation steps.

2. Documentation of specific quality assurance procedures
followed during sampling, sample preparation, sample
introduction, and analysis.

3. Measurement of the average accuracy and precision of the
specific procedures, including field duplicates and field
spiking of the off-site material source before or during
76
sampling with compounds having similar chemical
characteristics to the target analytes.

(I) Any other analysis method that has been validated in
accordance with the procedures specified in section 5.1 and
section 5.3 and the corresponding calculations in section 6.1 or
section 6.3 of Method 301 in appendix A in 40 CFR part 63. The
data are acceptable if they meet the criteria specified in section
6.1.5 or section 6.3.3 of Method 301. If correction is required
under section 6.3.3 of Method 301, the data are acceptable if the
correction factor is within the range of 0.7 to 1.30. Other sections
of Method 301 are not required.

(iii) Calculations. The average VOHAP concentration (C) on a mass-
weighted basis shall be calculated by using the results for all samples
analyzed in accordance with paragraph (2)(ii) of this section and the
following equation. The permittee using a test method that provides
species-specific chemical concentrations may adjust the measured
concentrations to the corresponding concentration values which would be
obtained had the off-site material samples been analyzed using Method
305. To adjust these data, the measured concentration for each individual
HAP chemical species contained in the off-site material is multiplied by
the appropriate species-specific adjustment factor (fm305) listed in Table 1
of 40 CFR 63 Subpart DD.

Where:

C = Average VOHAP concentration of the off-site material at the point-of-
delivery on a mass-weighted basis, ppmw.

i = Individual sample "i" of the off-site material.

n = Total number of samples of the off-site material collected (at least 4)
for the averaging period (not to exceed 1 year).

Qi = Mass quantity of off-site material stream represented by Ci, kg/hr.

QT = Total mass quantity of off-site material during the averaging period,
kg/hr.

Ci = Measured VOHAP concentration of sample "i" as determined in
accordance with the requirements of 40 CFR 63.694(a), ppmw.

(3) Knowledge of the off-site material to determine VOHAP concentration.

(i) Documentation shall be prepared that presents the information used as
the basis for the permittee's knowledge of the off-site material stream's
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average VOHAP concentration. Examples of information that may be used
as the basis for knowledge include: material balances for the source or
process generating the off-site material stream; species-specific chemical
test data for the off-site material stream from previous testing that are still
applicable to the current off-site material stream; previous test data for
other locations managing the same type of off-site material stream; or
other knowledge based on information in documents such as manifests,
shipping papers, or waste certification notices.

(ii) If test data are used as the basis for knowledge, then the permittee shall
document the test method, sampling protocol, and the means by which
sampling variability and analytical variability are accounted for in the
determination of the average VOHAP concentration. For example, the
permittee may use HAP concentration test data for the off-site material
stream that are validated in accordance with in Method 301 40 CFR part
63, appendix A of 40 CFR 63 as the basis for knowledge of the off-site
material.

(iii) The permittee using species-specific chemical concentration test data
as the basis for knowledge of the off-site material may adjust the test data
to the corresponding average VOHAP concentration value which would be
obtained had the off-site material samples been analyzed using Method
305. To adjust these data, the measured concentration for each individual
HAP chemical species contained in the off-site material is multiplied by
the appropriate species-specific adjustment factor (fm305) listed in Table 1
of 40 CFR 63 Subpart DD.

(iv) In the event that the Director and the permittee disagree on a
determination of the average VOHAP concentration for an off-site material
stream using knowledge, then the results from a determination of VOHAP
concentration using direct measurement as specified in paragraph (2) of
this section shall be used to establish compliance with the applicable
requirements of this condition. The Director may perform or request that
the permittee perform this determination using direct measurement.

(b) Procedure for determining no detectable organic emissions for the purpose of
complying with this condition.

(1) The test shall be conducted in accordance with the procedures specified in
Method 21 of 40 CFR part 60, appendix A. Each potential leak interface (i.e., a
location where organic vapor leakage could occur) on the cover and associated
closure devices shall be checked. Potential leak interfaces that are associated with
covers and closure devices include, but are not limited to: the interface of the cover
and its foundation mounting; the periphery of any opening on the cover and its
associated closure device; and the sealing seat interface on a spring-loaded
pressure-relief valve.

(2) The test shall be performed when the unit contains a material having a total
organic concentration representative of the range of concentrations for the
materials expected to be managed in the unit. During the test, the cover and closure
devices shall be secured in the closed position.

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(3) The detection instrument shall meet the performance criteria of Method 21 of
40 CFR part 60, appendix A, except the instrument response factor criteria in
section 3.1.2(a) of Method 21shall be for the average composition of the organic
constituents in the material placed in the unit, not for each individual organic
constituent.

(4) The detection instrument shall be calibrated before use on each day of its use
by the procedures specified in Method 21 of 40 CFR part 60, appendix A.

(5) Calibration gases shall be as follows:

(i) Zero air (less than 10 ppmv hydrocarbon in air); and

(ii) A mixture of methane or n-hexane in air at a concentration of
approximately, but less than, 10,000 ppmv.

(6) The permittee may choose to adjust or not adjust the detection instrument
readings to account for the background organic concentration level. If the
permittee chooses to adjust the instrument readings for the background level, the
background level value shall be determined according to the procedures in Method
21 of 40 CFR part 60, appendix A.

(7) Each potential leak interface shall be checked by traversing the instrument
probe around the potential leak interface as close to the interface as possible, as
described in Method 21. In the case when the configuration of the cover or closure
device prevents a complete traverse of the interface, all accessible portions of the
interface shall be sampled. In the case when the configuration of the closure device
prevents any sampling at the interface and the device is equipped with an enclosed
extension or horn (e.g., some pressure relief devices), the instrument probe inlet
shall be placed at approximately the center of the exhaust area to the atmosphere.

(8) The permittee shall determine if a potential leak interface operates with no
detectable emissions using the applicable procedure specified in paragraph (8)(i)
(8)(ii) of this section.

(i) If the permittee chooses not to adjust the detection instrument readings
for the background organic concentration level, then the maximum organic
concentration value measured by the detection instrument is compared
directly to the applicable value for the potential leak interface as specified
in paragraph (9) of this section.

(ii) If the permittee chooses to adjust the detection instrument readings for
the background organic concentration level, the value of the arithmetic
difference between the maximum organic concentration value measured by
the instrument and the background organic concentration value as
determined in paragraph (6) of this section is compared with the applicable
value for the potential leak interface as specified in paragraph (9) of this
section.

(9) A potential leak interface is determined to operate with no detectable emissions
using the applicable criteria specified in paragraphs (9)(i) and (9)(ii) of this
section.

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(i) For a potential leak interface other than a seal around a shaft that passes
through a cover opening, the potential leak interface is determined to
operate with no detectable organic emissions if the organic concentration
value determined in paragraph (8) is less than 500 ppmv.

(ii) For a seal around a shaft that passes through a cover opening, the
potential leak interface is determined to operate with no detectable organic
emissions if the organic concentration value determined in paragraph (8) is
less than 10,000 ppmv.

(c) Procedure for determining a container to be vapor-tight for the purpose of complying
with this condition.

(1) The test shall be performed in accordance with Method 27 of 40 CFR part 60,
appendix A of 40 CFR.

(2) A pressure measurement device shall be used that has a precision of ± 2.5 mm
water and that is capable of measuring above the pressure at which the container is
to be tested for vapor tightness.

(3) If the test results determined by Method 27 indicate that the container sustains
a pressure change less than or equal to 750 Pascals within 5 minutes after it is
pressurized to a minimum of 4,500 Pascals, then the container is determined to be
vapor-tight.

(d) The permittee shall inspect the containers greater than 0.1 m3 in size and its cover and
closure devices as follows:

(1) In the case when a regulated-material already is in the container at the time the
permittee first accepts possession of the container at the facility site and the
container is not emptied (i.e., does not meet the conditions for an empty container
as defined in this condition) within 24 hours after the container has been accepted
at the facility site, the container and its cover and closure devices shall be visually
inspected by the permittee to check for visible cracks, holes, gaps, or other open
spaces into the interior of the container when the cover and closure devices are
secured in the closed position. This inspection of the container shall be conducted
on or before the date that the container is accepted at the facility (i.e., the date that
the container becomes subject to the standards under this condition). For the
purpose of this requirement, the date of acceptance is the date that Clean Harbors
Aragonite first accepts custody, takes possession, or assumes responsibility for the
management of the container. If a defect is detected, the permittee shall repair the
defect in accordance with the requirements of paragraph (3) of this section.

(2) In the case when a container filled or partially filled with regulated-material
remains unopened at the facility site for a period of 1 year or more, the container
and its cover and closure devices shall be visually inspected by the permittee
initially and hereafter, at least once every calendar year, to check for visible cracks,
holes, gaps, other open spaces into the interior of the container when the cover and
closure devices are secured in the closed position. If a defect is detected, the
permittee shall repair the defect in accordance with the requirements of paragraph
(3) of this section.

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(3) When a defect is detected for the container, cover, or closure devices, the
permittee shall either empty the regulated-material from the defective container in
accordance with paragraph (3)(i) of this section or repair the defective container in
accordance with paragraph (3)(ii) of this section.

(i) If the permittee elects to empty the regulated-material from the
defective container, the permittee shall remove the regulated-material from
the defective container to meet the conditions for an empty container (as
defined in this condition) and transfer the removed regulated-material to
either a container that meets the applicable standards under this condition
or to a tank, process, or treatment unit that meets the applicable standards
under the subpart referencing this condition. Transfer of the regulated-
material shall be completed no later than 5 calendar days after detection of
the defect. The emptied defective container shall be either repaired,
destroyed, or used for purposes other than management of regulated-
material.

(ii) If the permittee elects not to empty the regulated-material from the
defective container, the permittee shall repair the defective container. First
efforts at repair of the defect shall be made no later than 24 hours after
detection and repair shall be completed as soon as possible but no later
than 5 calendar days after detection. If repair of a defect cannot be
completed within 5 calendar days, then the regulated-material shall be
emptied from the container and the container shall not be used to manage
regulated-material until the defect is repaired.

(e) Closed-vent system monitoring requirements. The permittee shall meet the following
inspection and monitoring requirements for the closed vent system required by this
condition:

(1) The closed-vent system shall be inspected and monitored in accordance with
the following requirements:

(i) At initial startup, the permittee shall monitor the closed-vent system
components and connections using the procedures specified in section (b)
of monitoring to demonstrate that the closed-vent system operates with no
detectable organic emissions.

(ii) After initial startup, the permittee shall inspect and monitor the closed-
vent system as follows:

(A) Closed-vent system joints, seams, or other connections that are
permanently or semi-permanently sealed (e.g., a welded joint
between two sections of hard piping or a bolted and gasketed
ducting flange) shall be visually inspected at least once per year to
check for defects that could result in air emissions. The permittee
shall monitor a component or connection using the procedures
specified in section (b) of monitoring to demonstrate that it
operates with no detectable organic emissions following any time
the component is repaired or replaced (e.g., a section of damaged
hard piping is replaced with new hard piping) or the connection is
unsealed (e.g., a flange is unbolted).

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(B) Closed-vent system components or connections other than
those specified in paragraph (1)(ii)(A) of this section, shall be
monitored at least once per year using the procedures specified in
section (b) of monitoring to demonstrate that components or
connections operate with no detectable organic emissions.

(iii) In the event that a defect or leak is detected, the permittee shall repair
the defect or leak in accordance with the requirements of paragraph (2) of
this section.

(2) The permittee shall repair all detected defects as follows:

(i) The permittee shall make first efforts at repair of the defect no later than
5 calendar days after detection and repair shall be completed as soon as
possible but no later than 45 calendar days after detection.

(ii) Repair of a defect may be delayed beyond 45 calendar days if either of
the conditions specified in paragraph (2)(ii)(A) or (2)(ii)(B) of this section
occurs. In this case, the permittee shall repair the defect the next time the
process or unit that vents to the closed-vent system is shutdown. Repair of
the defect shall be completed before the process or unit resumes operation.

(A) Completion of the repair is technically infeasible without the
shutdown of the process or unit that vents to the closed-vent
system.

(B) The permittee determines that the air emissions resulting from
the repair of the defect within the specified period would be
greater than the fugitive emissions likely to result by delaying the
repair until the next time the process or unit that vents to the
closed-vent system is shutdown.

(f) Control device monitoring requirements. The permittee shall ensure that each control
device operates properly by monitoring the control device in accordance with the
requirements specified in paragraphs (1) through (7) of this section.

(1) A continuous parameter monitoring system shall be used to measure the
operating parameter or parameters specified for the control device in this condition.
The continuous parameter monitoring system shall meet the following
specifications and requirements:

(i) The continuous parameter monitoring system shall measure either an
instantaneous value at least once every 15 minutes or an average value for
intervals of 15 minutes or less and continuously record either:

(A) Each measured data value; or

(B) Each block average value for each 1-hour period or shorter
periods calculated from all measured data values during each
period. If values are measured more frequently than once per
minute, a single value for each minute may be used to calculate the
hourly (or shorter period) block average instead of all measured
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values.

(ii) The monitoring system shall be installed, calibrated, operated, and
maintained in accordance with the manufacturer's specifications or other
written procedures that provide reasonable assurance that the monitoring
equipment is operating properly.

(2) Using the data recorded by the monitoring system, the permittee shall calculate
the daily average value for each monitored operating parameter for each operating
day. If operation of the control device is continuous, the operating day is a 24-hour
period. If control device operation is not continuous, the operating day is the total
number of hours of control device operation per 24-hour period. Valid data points
shall be available for 75 percent of the operating hours in an operating day to
compute the daily average.

(3) For each monitored operating parameter, the permittee shall establish a
minimum operating parameter value or a maximum operating parameter value, as
appropriate, to define the range of conditions at which the control device shall be
operated to continuously achieve the applicable performance requirements
specified in the condition. The minimum or maximum operating parameter value
shall be established based on the control device design analysis and supplemented,
as necessary, by the control device manufacturer recommendations or other
applicable information.

(4) An excursion for a given control device is determined to have occurred when
the monitoring data or lack of monitoring data result in any one of the criteria
specified in paragraphs (4)(i) through (4)(iii) of this section being met. When
multiple operating parameters are monitored for the same control device and
during the same operating day more than one of these operating parameters meets
an excursion criterion specified in paragraphs (4)(i) through (4)(iii) of this section,
then a single excursion is determined to have occurred for the control device for
that operating day.

(i) An excursion occurs when the daily average value of a monitored
operating parameter is less than the minimum operating parameter limit
(or, if applicable, greater than the maximum operating parameter limit)
established for the operating parameter in accordance with the
requirements of paragraph (3) of this section.

(ii) An excursion occurs when the period of control device operation is 4
hours or greater in an operating day and the monitoring data are
insufficient to constitute a valid hour of data for at least 75 percent of the
operating hours. Monitoring data are insufficient to constitute a valid hour
of data if measured values are unavailable for any of the 15-minute periods
within the hour.

(iii) An excursion occurs when the period of control device operation is
less than 4 hours in an operating day and more than 1 of the hours during
the period does not constitute a valid hour of data due to insufficient
monitoring data. Monitoring data are insufficient to constitute a valid hour
of data if measured values are unavailable for any of the 15-minute periods
within the hour.

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(5) For each excursion, except as provided for in paragraph (6) of this section, the
permittee shall be deemed to have failed to have applied control in a manner that
achieves the required operating parameter limits. Failure to achieve the required
operating parameter limits is a violation of this standard.

(6) An excursion is not a violation of this standard under any one of the conditions
specified in paragraphs (6)(i) and (6)(ii) of this section.

(i) An excursion is not a violation nor does it count toward the number of
excused excursions allowed under paragraph (6)(ii) of this section when
the excursion occurs during any one of the following periods:

(A) During a period of startup, shutdown, or malfunction when the
affected facility is operated during such period in accordance with
the facility's startup, shutdown, and malfunction plan; or

(B) During periods of non-operation of the unit or the process that
is vented to the control device (resulting in cessation of HAP
emissions to which the monitoring applies).

(ii) For each control device, one excused excursion is allowed per
semiannual period for any reason. The initial semiannual period is the 6-
month reporting period addressed by the first semiannual report submitted
by the permittee in accordance with paragraph (b)(3) of reporting.

(7) Nothing in paragraphs (1) through (6) of this section shall be construed to allow
or excuse a monitoring parameter excursion caused by any activity that violates
other applicable provisions of this condition.

II.B.4.b.2 Recordkeeping:

(a) The permittee shall comply with the recordkeeping requirements in 40 CFR 63.10 under 40
CFR 63 subpart A-General Provisions that are applicable to this condition as specified in Table
2 of 40 CFR 63 Subpart DD.

(b) The permittee shall maintain the records in accordance with the requirements of 40 CFR
63.10 and Section I.S.1 of this permit.

(c) The permittee shall record, on a semiannual basis, the information specified in paragraphs
(1) and (2) of this section for those planned routine maintenance operations that would require
the control device not to meet the requirements of this condition.

(1) A description of the planned routine maintenance that is anticipated to be performed
for the control device during the next 6 months. This description shall include the type
of maintenance necessary, planned frequency of maintenance, and lengths of
maintenance periods.

(2) A description of the planned routine maintenance that was performed for the control
device during the previous 6 months. This description shall include the type of
maintenance performed and the total number of hours during these 6 months that the
control device did not meet the requirement of this condition, due to planned routine
maintenance.
84
(d) The permittee shall record the information specified in paragraphs (1) through (3) of this
section for those unexpected control device system malfunctions that would require the control
device not to meet the requirements of this condition.

(1) The occurrence and duration of each malfunction of the control device system.

(2) The duration of each period during a malfunction when gases, vapors, or fumes are
vented from the waste management unit through the closed-vent system to the control
device while the control device is not properly functioning.

(3) Actions taken during periods of malfunction to restore a malfunctioning control
device to its normal or usual manner of operation.

II.B.4.b.3 Reporting:

(a) The permittee shall comply with the reporting requirements in Section I of this permit. In
addition, the permittee shall comply with the notification requirements specified in paragraph
(a)(1) of this section and the reporting requirements specified in paragraph (a)(2) of this section.

(1) The Permittee shall submit notices to the Director in accordance with the
applicable notification requirements in 40 CFR 63.9 as specified in Table 2 of 40 CFR
63 Subpart DD.

(2) The Permittee shall submit reports to the Director in accordance with the applicable
reporting requirements in 40 CFR 63.10 as specified in Table 2 of 40 CFR 63 Subpart
DD.

(b) The Permittee shall submit the following notifications and reports to the Director:

(1) A Notification of Performance Tests specified in 40 CFR 63.9(g) of 40 CFR 63,

(2) Startup, shutdown, and malfunction reports specified in this permit.

(i) If actions taken by the permittee during a startup, shutdown, or
malfunction of an affected emission unit (including actions taken to correct a
malfunction) are not completely consistent with the procedures specified in the
source's startup, shutdown, and malfunction plan, the permittee shall state such
information in the report. The startup, shutdown, or malfunction report shall
consist of a letter, containing the name, title, and signature of the responsible
official who is certifying its accuracy, that shall be submitted to the Director,
and

(ii) Separate startup, shutdown, or malfunction reports are not required if the
information is included in the summary report specified in paragraph (b)(3)of
this section.

(3) A summary report specified in this permit of 40 CFR 63 shall be submitted on a
semiannual basis (i.e., once every 6-month period). The summary report shall include a
description of all excursions as defined in paragraph (4) of section (f) of monitoring of
this condition that have occurred during the 6-month reporting period. For each
excursion caused when the daily average value of a monitored operating parameter is
less than the minimum operating parameter limit (or, if applicable, greater than the
85
maximum operating parameter limit), the report shall include the daily average values
of the monitored parameter, the applicable operating parameter limit, and the date and
duration of the period that the exceedance occurred. For each excursion caused by lack
of monitoring data, the report shall include the date and duration of period when the
monitoring data were not collected and the reason why the data were not collected.

(c) For Container Level 3 controls used in accordance with the provisions of this condition the
permittee shall prepare and maintain records for the most recent set of calculations and
measurements performed by the permittee to verify that the enclosure meets the criteria of a
permanent total enclosure as specified in "Procedure T-Criteria for and Verification of a
Permanent or Temporary Total Enclosure" under 40 CFR 52.741, Appendix B.

(d) The permittee shall send a copy of each report submitted to the Director to Region 8 of the
EPA to the address given in Section I of this permit.

Status: In compliance - VOHAP information is contained on profile sheets attached to each waste
container. Containers using Container Level 1 controls utilize sealed containers. No open
containers are accepted. An LEL detection system is in the repack and decant rooms to detect
leaks. Containers are marked according to U.S. DOT regulations. Contents being transferred
from containers using Level 2 controls are covered in a blanket of N2 or are vented to the kiln.
Containers using Container Level 3 controls are not to be accepted. Daily inspections of
containers greater than 0.1 m3 in size are performed and logged. If a defect is detected, the
container is taken to a “repack room” and either repaired or emptied. Clean Harbors does not
store containers with waste for longer than 1 year. Carbon bed replacements for the bulk solids
stream are based on stream composition and constituent concentrations. Carbon canisters are
tested every three hours (when active) by PID (Method 21). Tanks are blanketed with N2 when
emptied. Reports are submitted to DEQ.
II.B.5 Conditions on Off-Site Material Transfer Systems (TRNS)

II.B.5.a Condition:

40 CFR Part 63, Subpart DD

(I) Affected Transfer systems

(a) For each transfer system, the permittee shall meet the requirements in either paragraph
(1), or (2) of this section. Transfer system means a stationary system for which the predominant
function is to convey liquids or solid materials from one point to another point within a waste
management operation or recovery operation. For the purpose of this condition, the conveyance
of material using a container (as defined for this condition) or a self-propelled vehicle (e.g., a
front-end loader) is not a transfer system. Examples of a transfer system include but are not
limited to a pipeline, an individual drain system, a gravity-operated conveyor (such as a chute),
and a mechanically-powered conveyor (such as a belt or screw conveyor).

(1) Control air emissions from the transfer system in accordance with the applicable
standards specified in section II of this condition.

(2) Determine before placing off-site material in the transfer system that the average
VOHAP concentration of the off-site material is less than 500 parts per million by
weight (ppmw) at the point-of-delivery. The permittee shall perform an initial
determination of the average VOHAP concentration of the off-site material using the
procedures specified in this permit for containers subject to 40 CFR 63 Subpart DD.
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This initial determination shall be performed before the first time any portion of the off-
site material stream is placed in the transfer system. Thereafter, the permittee shall
review and update, as necessary, this determination at least once every calendar year
following the date of the initial determination for the off-site material stream.

(b) A transfer system is exempted from the requirements in paragraph (a) of this section if the
off-site material placed in the unit is a hazardous waste that meets the conditions specified in
either paragraph (1) or (2).

(1) The hazardous waste meets the numerical organic concentration limits,
applicable to the hazardous waste, as specified in 40 CFR part 268¿Land Disposal
Restrictions, listed in the table, "Treatment Standards for Hazardous Waste" in 40 CFR
268.40.

(2) The organic hazardous constituents in the hazardous waste have been treated by
the treatment technology established by the EPA for the hazardous waste in 40 CFR
268.42(a), or have been removed or destroyed by an equivalent method of treatment
approved by the EPA under 40 CFR 268.42(b).

(II) Standards: Transfer systems.

(a) For each affected transfer system, the permittee shall control air emissions by a transfer
system that consists of continuous hard-piping. Hard-piping means pipe or tubing that is
manufactured and properly installed in accordance with relevant standards and good
engineering practices. All joints or seams between the pipe sections shall be permanently or
semi-permanently sealed (e.g., a welded joint between two sections of metal pipe or a bolted and
gasketed flange). [Authority granted under 40 CFR 63.689; condition originated in 40 CFR 63
Subpart DD]

II.B.5.a.1 Monitoring:

Each transfer system subject to this condition shall be visually inspected by the permittee
initially and thereafter, at least once every calendar year, to check that the transfer system
consists of continuous hard-piping and all joints or seams between the pipe sections are
permanently or semi-permanently sealed.

II.B.5.a.2 Recordkeeping:

(a) The permittee shall comply with the recordkeeping requirements in 40 CFR 63.10 under 40
CFR 63 subpart A: General Provisions that are applicable to this condition as specified in Table
2 of 40 CFR 63 Subpart DD.

(b) The permittee shall maintain the records in accordance with the requirements of 40 CFR
63.10 of 40 CFR 63 and Section I.S.1 of this permit.

II.B.5.a.3 Reporting:

(a) The permittee shall comply with the reporting requirements in Section I of this permit. In
addition, the permittee shall comply with the notification requirements specified in paragraph
(a)(1) of this section and the reporting requirements specified in paragraph (a)(2) of this section.

(1) The permittee shall submit notices to the Director in accordance with the
applicable notification requirements in 40 CFR 63.9 as specified in Table 2 of 40 CFR
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63 Subpart DD.

(2) The permittee shall submit reports to the Director in accordance with the
applicable reporting requirements in 40 CFR 63.10 as specified in Table 2 of 40 CFR
63 Subpart DD.

(b) The permittee shall send a copy of each report submitted to the Director to Region 8 of the
EPA to the address given in Section I of this permit. [R307-415-6a]

Status: In compliance – The material transfer systems consist of covers and hard-piping, it is
considered to be self-contained. The system is visual inspected and the FID (Method 21) is also
used to detect for leaks on a quarterly basis. Inspection results are entered into the CHATEAU
database in accordance with Subparts DD and V. Waste profile sheets accompany each container
of waste and list the required information.

II.B.6 Conditions on Off-Site Material Tanks (TNKS)

II.B.6.a Condition:

(I) Tank Management

(a) The permittee shall meet the following standards for each affected tank

(1) The permittee shall install, operate, and maintain a fixed-roof and closed-vent
system that routes all organic vapors vented from the tank to a control device meeting
the requirements in section II of this condition. The fixed-roof shall meet the following
requirements:

(i) The cover and all openings (e.g., access hatches, sampling ports, and gauge
wells) shall be designed to operate with no detectable emissions as indicated by
an instrument reading less than 500 ppmv above background, as determined
initially and thereafter at least once per year by the methods specified in (c) of
monitoring.

(ii) Each opening shall be maintained in a closed, sealed position (e.g., covered by
a lid that is gasketed and latched) at all times that waste is in the tank except when
it is necessary to use the opening for waste sampling or removal, or for equipment
inspection, maintenance, or repair.

(iii) If the cover and closed-vent system operate such that the tank is maintained at
a pressure less than atmospheric pressure, then paragraph (a)(1)(ii) of this section
does not apply to any opening that meets all of the following conditions:

(A) The purpose of the opening is to provide dilution air to reduce
the explosion hazard;

(B) The opening is designed to operate with no detectable emissions
as indicated by an instrument reading of less than 500 ppmv above
background, as determined initially and thereafter at least once per year
by the methods specified in (c) of monitoring; and

(C) The pressure is monitored continuously to ensure that the
pressure in the tank remains below atmospheric pressure.
88

(2) Or, the permittee must install, operate, and maintain an enclosure and closed-
vent system that routes all organic vapors vented from the tank, located inside the
enclosure, to a control device in accordance with the requirements specified in
paragraph (d) below.

(b) Each fixed-roof, seal, access door, and all other openings shall be checked by visual inspection
initially and quarterly thereafter to ensure that no cracks or gaps occur and that access doors and
other openings are closed and gasketed properly.

(c) Except as provided in IV of this condition, when a broken seal or gasket or other
problem is identified, or when detectable emissions are measured, first efforts at repair shall be made
as soon as practicable, but not later than 45 calendar days after identification.

(d) If the permittee controls air pollutant emissions by using an enclosure vented through a closed-
vent system to a control device, the following requirements must be met:

(1) The tank must be located inside a total enclosure. The enclosure must be
designed and operated in accordance with the criteria for a permanent total enclosure as
specified in "Procedure T-Criteria for and Verification of a Permanent or Temporary
Total Enclosure" in 40 CFR 52.741, appendix B. The enclosure may have permanent or
temporary openings to allow worker access; passage of material into or out of the
enclosure by conveyor, vehicles, or other mechanical means; entry of permanent
mechanical or electrical equipment; or direct airflow into the enclosure. The owner or
operator must perform the verification procedure for the enclosure as specified in
section 5.0 of Procedure T initially when the enclosure is first installed and, thereafter,
annually. A facility that has conducted an initial compliance demonstration and that
performs annual compliance demonstrations in accordance with the requirements for
Tank Level 2 control requirements 40 CFR 264.1084(i) or 40 CFR 265(i)is not required
to make repeat demonstrations of initial and continuous compliance for the purposes of
this subpart.

(2) The enclosure must be vented through a closed-vent system to a control device
that is designed and operated in accordance with the standards for control devices
specified in 40 CFR 61.349.

(3) Safety devices, as defined in 40 CFR Part 61.341, may be installed and operated
as necessary on any enclosure, closed-vent system, or control device used to comply
with the requirements of paragraphs (1) and (2) above.

(4) The closed-vent system must be designed and operated in accordance with the
requirements of 40 CFR 61.349.

(II) Closed Vent System and Control Device

(a) The closed-vent system and control device shall be designed and operated in accordance
with the following requirements.

(1) The closed-vent system shall:

(i) Be designed to operate with no detectable emissions as indicated by an
instrument reading of less than 500 ppmv above background, as determined
initially and thereafter at least once per year by the methods specified in (c) of
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monitoring.

(ii) All gauging and sampling devices shall be gas-tight except when
gauging or sampling is taking place.

(2) The control devices shall be designed and operated in accordance with the
following conditions:

(i) The incinerator shall provide a minimum residence time of 0.5 seconds
at a minimum temperature of 760°C (1,400 °F).

(ii) The carbon adsorption systems shall recover or control the organic
emissions vented to it with an efficiency of 95 weight percent or greater.

(b) The closed-vent system and incinerator or carbon adsorption system shall be operated at
all times when waste is placed or present in an affected tank and the tank is vented to the
incinerator or carbon adsorption system.

(c) The permittee shall demonstrate that each control device achieves the appropriate
conditions specified in paragraph (a)(2) of this section by using engineering calculations in
accordance with requirements specified in (e) of recordkeeping.

(d) The Director may request at any time the permittee demonstrate that a control device meets
the applicable conditions specified in paragraph (a)(2) of this section by conducting a
performance test using the test methods and procedures as required in 40 CFR 61.355.

(e) Each closed-vent system and control device shall be visually inspected initially and
quarterly thereafter. The visual inspection shall include inspection of ductwork and piping and
connections to covers and control devices for evidence of visible defects such as holes in
ductwork or piping and loose connections.

(f) Except as provided in section IV of this condition, if visible defects are observed during
an inspection, or if other problems are identified, or if detectable emissions are measured, a first
effort to repair the closed-vent system and control device shall be made as soon as practicable
but no later than 5 calendar days after detection. Repair shall be completed no later than 15
calendar days after the emissions are detected or the visible defect is observed.

(III) Treatment Standards

(a) Incinerator

(1) The permittee shall treat affected waste in affected tanks in accordance with the
following requirements:

(i) The permittee shall design, install, operate, and maintain a treatment
process that destroys benzene in the waste by incinerating the waste in a
combustion unit that achieves a destruction efficiency of 99 percent or greater
for benzene.

(ii) The permittee may aggregate or mix together individual wastes to create
a combined waste for the purpose of facilitating treatment of waste to comply
with the requirements of paragraph (a)(1)(i) of this section.

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(2) A treatment process is in compliance with the requirements of this condition
provided that the permittee has been issued a final permit under 40 CFR part 270 and
complies with the requirements of 40 CFR part 264, subpart 0.

(3) Except as specified in paragraph (a)(3)(iii) of this section, if the treatment
process has any openings (e.g., access doors, hatches, etc.), all such openings shall be
sealed (e.g., gasketed, latched, etc.) and kept closed at all times when waste is being
treated, except during inspection and maintenance.

(i) Each seal, access door, and all other openings shall be checked by visual
inspections initially and quarterly thereafter to ensure that no cracks or gaps
occur and that openings are closed and gasketed properly.

(ii) Except as provided in section IV of this condition, when a broken seal or
gasket or other problem is identified, first efforts at repair shall be made as soon
as practicable, but not later than 15 calendar days after identification.

(iii) If the cover and closed-vent system operate such that the treatment
process is maintained at a pressure less than atmospheric pressure, the permittee
may operate the system with an opening that is not sealed and kept closed at all
times if the following conditions are met:

(A) The purpose of the opening is to provide dilution air to reduce
the explosion hazard;

(B) The opening is designed to operate with no detectable emissions
as indicated by an instrument reading of less than 500 ppmv above
background, as determined initially and thereafter at least once per
year by the methods specified in (c) of monitoring; and

(C) The pressure is monitored continuously to ensure that pressure in
the treatment process remains below atmospheric pressure.

(b) Send Offsite

(1) Rather than treating the waste onsite, the permittee may elect to transfer affected
wastes offsite to another facility where the waste is treated in accordance with the
requirements of 40 CFR 60.342(c)(1)(i). If the permittee transfers the waste offsite, the
permittee shall:

(i) Comply with the standards of this condition prior to shipment of the
waste offsite.

(ii) Include with each offsite waste shipment a notice stating that the waste
contains benzene which is required to be managed and treated in accordance
with the provisions of 40 CFR 61 Subpart FF.

(IV) Delay of repair.

(a) Delay of repair will be allowed if the repair is technically impossible without a complete
or partial facility or unit shutdown.

(b) Repair of such equipment shall occur before the end of the next facility or unit
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shutdown.

[Authority granted under 40 CFR 61.343; condition originated in 40 CFR 61 Subpart FF].

II.B.6.a.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate according to the manufacturer's
specifications a device to continuously monitor the control device operation as specified in the
following paragraphs. The permittee shall inspect at least once each operating day the data
recorded by the monitoring equipment (e.g., temperature monitor or flow indicator) to ensure
that the control device is operating properly.

(1) For the incinerator, a temperature-monitoring device equipped with a continuous
recorder. The device shall have an accuracy of ±1 percent of the temperature being
monitored in °C or ±0.5°C, whichever is greater. The temperature sensor shall be
installed at a representative location in the combustion chamber.

(b) The permittee shall replace the carbon in the carbon adsorption system with fresh carbon at
a regular predetermined time interval that is less than the carbon replacement interval that is
determined by the maximum design flow rate and either the organic concentration or the
benzene concentration in the gas stream vented to the carbon adsorption system.

(c) The permittee shall test equipment for compliance with no detectable emissions in
accordance with the following requirements:

(1) Monitoring shall comply with Method 21 from appendix A of 40 CFR part 60.

(2) The detection instrument shall meet the performance criteria of Method 21.

(3) The instrument shall be calibrated before use on each day of its use by the
procedures specified in Method 21.

(4) Calibration gases shall be:

(i) Zero air (less than 10 ppm of hydrocarbon in air); and

(ii) A mixture of methane or n-hexane and air at a concentration of
approximately, but less than, 10,000 ppm methane or n-hexane.

(5) The background level shall be determined as set forth in Method 21.

(6) The instrument probe shall be traversed around all potential leak interfaces as
close as possible to the interface as described in Method 21.

(7) The arithmetic difference between the maximum concentration indicated by the
instrument and the background level is compared to 500 ppm for determining
compliance.

(8) For each system using an emission control that is maintained at a pressure less
than atmospheric pressure with openings to provide dilution air, the permittee shall
install, calibrate, maintain, and operate according to the manufacturer's specifications a
device equipped with a continuous recorder to monitor the pressure in the unit to ensure
that it is less than atmospheric pressure.
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II.B.6.a.2 Recordkeeping:

(a) The permittee shall comply with the recordkeeping requirements of section I.S.1 of this
permit. In addition, each record shall be maintained in a readily accessible location at the
facility site for a period not less than five years from the date the information is recorded unless
otherwise specified.

(b) The permittee transferring waste off-site to another facility for treatment documentation for
each offsite waste shipment that includes the following information: Date waste is shipped
offsite, quantity of waste shipped offsite, name and address of the facility receiving the waste,
and a copy of the notice sent with the waste shipment.

(c) The permittee shall maintain engineering design documentation for all control equipment
required by this condition that is installed on the tanks. The documentation shall be retained for
the life of the control equipment.

(d) The permittee shall maintain the following records for the treatment unit. The
documentation shall be retained for the life of the unit. A statement signed and dated by the
Permittee certifying that the unit is permitted as a 40 CFR 264 Subpart O incinerator.

(e) For the closed-vent systems and control devices, the permittee shall maintain the following
records. The documentation shall be retained for the life of the control devices.

(1) A statement signed and dated by the permittee certifying that the closed-vent
systems and control devices are designed to operate at the documented performance

level when the waste management unit vented to the control device is or would be
operating at the highest load or capacity expected to occur.

(2) A design analysis for the control device that includes for example:

(i) Specifications, drawings, schematics, and piping and instrumentation
diagrams prepared by the permittee, or the control device manufacturer ordor
vendor that describe the control device design based on acceptable engineering
texts. The design analysis shall address the following vent stream characteristics
and control device operating parameters:

(A) For the incinerator, the design analysis shall consider the vent
stream composition, constituent concentrations, and flow rate. The
design analysis shall also establish the design minimum and average
temperature in the combustion zone and the combustion zone residence
time.

(B) For the carbon adsorption systems, the design analysis shall
consider the vent stream composition, constituent concentration, flow
rate, relative humidity, and temperature. The design analysis shall also
establish the design exhaust vent stream organic compound
concentration level or the design exhaust vent stream benzene
concentration level, capacity of carbon bed, type and working capacity
of activated carbon used for carbon bed, and design carbon
replacement interval based on the total carbon working capacity of the
control device and source operating schedule.
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(f) The permittee shall maintain a record for each visual inspection that identifies a problem
(such as a broken seal, gap or other problem) which could result in benzene emissions. The
record shall include the date of the inspection, waste management unit and control equipment
location where the problem is identified, a description of the problem, a description of the
corrective action taken, and the date the corrective action was completed. .

(g) The permittee shall maintain a record for each test of no detectable emissions. The
record shall include the following information: date the test is performed, background level
measured during test, and maximum concentration indicated by the instrument reading
measured for each potential leak interface. If detectable emissions are measured at a leak
interface, then the record shall also include the waste management unit, control equipment, and
leak interface location where detectable emissions were measured, a description of the problem,
a description of the corrective action taken, and the date the corrective action was completed.

(h) The permittee shall maintain documentation that includes the following information
regarding the treatment unit operation:

(1) Dates of startup and shutdown of the unit.

(2) Periods when the unit is not operated as designed.

(i) For each control device, the permittee shall maintain documentation that
includes the following information regarding the control device operation:

(1) Dates of startup and shutdown of the closed-vent system and control device.

(2) A description of the operating parameter (or parameters) to be monitored to
ensure that the control device will be operated in conformance with these standards and
the control device's design specifications and an explanation of the criteria used for
selection of that parameter (or parameters). This documentation shall be kept for the life
of the control device.

(3) Periods when the closed-vent system and control device are not operated as
designed.

(4) The permittee shall maintain continuous records of the temperature of the gas
stream in the combustion zone of the incinerator and records of all 3-hour periods of
operation during which the average temperature of the gas stream in the combustion
zone is more than 28°C (50 °F) below the design combustion zone temperature.

(5) The permittee shall record each occurrence when the vent stream continues to
flow through the control device beyond the predetermined carbon bed regeneration
time.

(6) For the carbon absorbers, the permittee shall maintain records of dates and times
when the control device is monitored, and shall record the date and time that the
existing carbon in the control device is replaced with fresh carbon.

(j) If a system is used for emission control that is maintained at a pressure less than
atmospheric pressure with openings to provide dilution air, then the permittee shall maintain
records of the monitoring device and records of all periods during which the pressure in the unit
is operated at a pressure that is equal to or greater than atmospheric pressure.

94
(k) If a total enclosure is used to comply with the control requirements for tanks, then the
permittee must keep records (1) and (2) listed below. The permittee may use records as required
in 40 CFR 264.1089(b)(2)(iv) or 40 CFR 265.1090(b)(2)(iv) to meet the recordkeeping
requirement in paragraph (1) below. The permittee must make the records of each
verification of a total enclosure available for inspection upon request.

(1) Records of the most recent set of calculations and measurements performed to
verify that the enclosure meets the criteria of a permanent total enclosure as specified in
"Procedure T-Criteria for and Verification of a Permanent or Temporary Total
Enclosure" in 40 CFR 52.741, appendix B;

(2) Records required for a closed-vent system and control device according to the
requirements in paragraphs (d), (f) and (j) above.

II.B.6.a.3 Reporting:

(a) The permittee shall comply with the reporting requirements in Section I of this Permit. In
addition, the permittee shall submit a report that includes the following information according
to the schedule provided below.

(b) The permittee shall submit to the Director the following reports:

(1) Prior to the date the total annual benzene quantity from waste received from
applicable waste generators is equal to or greater than 10 Mg/yr , a certification that the
equipment necessary to comply with these standards has been installed and that the
required initial inspections or tests have been carried out in accordance with this
condition.

(2) Beginning 3 months after the date that the equipment necessary to comply with
these standards has been certified in accordance with paragraph (b)(1) of this section,
the permittee shall submit quarterly to the Director a certification that all of the required
inspections have been carried out in accordance with the requirements of this condition.

(3) Beginning 3 months after the date that the equipment necessary to comply with
these standards has been certified in accordance with paragraph (b)(1) of this section,
the permittee shall submit a report quarterly to the Director that includes:

(i) Each period of operation monitored during which any of the following
conditions occur, as applicable to the control device:

(A) Each 3-hour period of operation during which the average
temperature of the gas stream in the combustion zone of the incinerator,
as measured by the temperature monitoring device, is more than 28°C
(50 °F) below the design combustion zone temperature.

(B) Each occurrence when the carbon in a carbon adsorber system is
not replaced at the predetermined interval.

(ii) For a cover and closed-vent system monitored in accordance with (d) of
monitoring, the permittee shall submit a report quarterly to the Director that
identifies any period in which the pressure in the unit is equal to or greater than
atmospheric pressure.

95

(4) Beginning one year after the date that the equipment necessary to comply with
these standards has been certified in accordance with paragraph (b)(1) of this section,
the permittee shall submit annually to the Director a report that summarizes all
inspections during which detectable emissions are measured or a problem (such as a
broken seal, gap or other problem) that could result in benzene emissions is identified,
including information about the repairs or corrective action taken.

(c) Reserved.

(d) The permittee shall send a copy of each report submitted to the Director, to Region 8 of the
EPA, to the address given in Section I of this permit.

Status: In compliance – The off-site material tanks are included under the LDAR program. The FID
(method 21) is part of the LDAR program.

Monitoring devices for temperature and pressure are installed and operated accordingly.

Organic vapors are vented to the incinerator or carbon system. The carbon beds of the carbon
absorption system are replaced on regular intervals. The replaced carbon beds are incinerated
rather than regenerated.

Records are maintained per RCRA permit requirements. The Design Analysis was submitted, to
the DAQ, with the NOI.

The bulk solids tank is located inside a permanent total enclosure. This is specified in the annual
Procedure Off-Line Total Enclosure Test which was performed on March 7, 2025, and the
Procedure On-Line Total Enclosure Test which was performed on March 21, 2025. The test
results will be submitted promptly (within 7 days).

All Quarterly Benzene NESHAP reports for calendar year 2024 have been submitted. The First
Quarter Benzene report for 2025, will be submitted in April of 2025.

II.B.7 Conditions on Soda Ash Bin.

II.B.7.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under R307-401-8;
condition originated in DAQE-AN107250026A-16]

II.B.7.a.1 Monitoring:

If an affected emission unit is operated during a calendar quarter, an opacity observation of the
emission unit shall be performed in the quarter that the emission unit was operated. The opacity
observation can be conducted at anytime during the quarter. The opacity observation shall be
conducted by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9, while the emission unit is operating. If visible emissions other than condensed water
vapor are observed from the emission unit, an opacity determination of that emission unit shall
be performed by a certified observer within 24 hours of the initial visual emission observation.
The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A,
Method 9
96
II.B.7.a.2 Recordkeeping:

Results from opacity observations and all data required by 40 CFR 60, Appendix A, Method 9
shall be recorded and maintained in accordance with Provision I.S.1 of this permit.

II.B.7.a.3 Recordkeeping:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The quarterly soda ash bin visual opacity observation records were
reviewed at time of the inspection. The last quarterly visual opacity observation was conducted on
October 3, 2024, and had an opacity of < 10 %.

II.B.8 Conditions on Carbon Silo

II.B.8.a Condition:

Visible emissions shall be no greater than 10 percent opacity. [Authority granted under R307-401-8;
condition originated in DAQE-AN107250026A-16].

II.B.8.a.1 Monitoring:

If an affected emission unit is operated during a calendar quarter, an opacity observation of the
emission unit shall be performed in the quarter that the emission unit was operated. The opacity
observation can be conducted at any time during the quarter. The opacity observation shall be
conducted by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9, while the emission unit is operating If visible emissions other than condensed water
vapor are observed from the emission unit, an opacity determination of that emission unit shall
be performed by a certified observer within 24 hours of the initial visual emission observation.
The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A,
Method 9.

II.B.8.a.2 Recordkeeping:

Results from opacity observations and all data required by 40 CFR 60, Appendix A, Method 9
shall be recorded and maintained in accordance with Provision I.S.1 of this permit.

II.B.8.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The quarterly carbon silo visual opacity observation records were
reviewed at time of the inspection. The last quarterly visual opacity observation was conducted on
October 6, 2024, and had an opacity of < 10 %.

97
II.B.9 Conditions on Emergency Generators.

II.B.9.a Condition:

Emergency generators shall be used for electricity producing operation only during the periods when
electric power from the public utilities is interrupted or during maintenance.

[Authority granted under R307-401-8; condition originated in DAQE-AN107250026A-16]

II.B.9.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.9.a.2 Recordkeeping:

Records of hours of operation for maintenance firing purposes and emergency use shall be kept
on a monthly basis for each affected emission unit Results of monitoring shall be maintained as
described in Provision I.S.1 of this permit.

II.B.9.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The two emergency generators both have non-resettable hour meters. The
generators are maintenance checked 10-15 minutes per week. Generator hours of operation are
tracked in the FAM database. It should be noted that emergency hours and maintenance hours
are not separated out. The maintenance hours were deducted using 15 minutes of maintenance
hours per week. The generator’s hours of operation are as follows:

Generator Emergency Hours Maintenance Hours 12-Month Period
Diesel – (Big E) 28.6 hrs. 12.0 hrs. 2024
Propane 0.0 8.0 hrs. 2024

II.B.9.b Condition:

Visible emissions shall be no greater than 10 percent opacity.

[Authority granted under R307- 401-8; condition originated in DAQE-AN107250026A-16]

II.B.9.b.1 Monitoring:

If an affected emission unit is operated during a calendar quarter, an opacity observation of the
emission unit shall be performed in the quarter that the emission unit was operated. The opacity
observation can be conducted at any time during the quarter. The opacity observation shall be
conducted by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9, while the emission unit is operating. If visible emissions other than condensed water
vapor are observed from the emission unit, an opacity determination of that emission unit shall
be performed by a certified observer within 24 hours of the initial visual emission observation.
The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A,
Method 9.
98
II.B.9.b.2 Recordkeeping:

Results from opacity observations and all data required by 40 CFR 60, Appendix A, Method 9
shall be recorded and maintained in accordance with Provision I.S.1 of this permit.

II.B.9.b.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The quarterly emergency generator visual opacity observation (method 9)
records were reviewed at time of the inspection. The Big E engine and the propane engine were
both observed on December 30, 2024. Both engines had an opacity of < 10 %.

II.B.9.c Condition:

(A) The 175 kW propane fired generator may not exceed the following emission standards:

(1) HC + NOX ... 3.8 g/kW-hr, and

(2) CO... 6.5 g/kW-hr.

(B) The permittee may use the following formula to determine alternate emissions standards in lieu of
the above values:

(HC + NOX) x CO0.791 ≤16.78.

Where the engine may not exceed:

(1) HC + NOX….3.8 g/kW-hr; and

(2) CO .. 31.0 g/kW-hr.

[Authority: 40 CFR Part 63, Subpart ZZZZ, 40 CFR Part 60, Subpart JJJJ. Origin: 40 CFR 63.6590(c),
40 CFR 60.4233(f)(3), 40 CFR 60.4233(c), 40 CFR 60.4231(c), 40 CFR 1048.101(c)]

II.B.9.c.1 Monitoring:

A performance test shall be conducted to demonstrate compliance with emissions standards. [40
CFR Part 60.4243(c)].

Emissions shall be measured using the applicable-testing procedures given in 40 CFR 1048,
Subpart F. [40 CFR 60.4233(h), and 40 CFR 1048.101(c)(1)].

II.B.9.c.2 Recordkeeping:

Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

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II.B.9.c.3 Reporting:

The permittee shall submit a copy of each performance test as conducted in 40 CFR 60.4244
within 60 days after the test has been completed.

Status: N/A – The statute of limitations for stack testing of the propane fired generator has expired. See
attached correspondence of the 2023 inspection memo. Visual opacity observations are still
conducted of the propane engine. See status of condition II.B.9.b.

II.B.9.d Condition:

(A) The permittee must operate the 175-kW propane fired generator according to the requirements in (1)
through (3) below to be considered an emergency stationary-engine. Any operation other than
emergency operation, maintenance and testing, emergency demand response, and operation in non-
emergency situations for 50 hours per year, as described in (1) through (3) below, is prohibited. If the
engine is not operated according to the requirements in (1) through (3) below, it will not be considered
an emergency engine and will be subject to all requirements for non-emergency engines.

(1) There is no time limit on the use of emergency stationary ICE in emergency situations.

(2) The permittee may operate the emergency stationary ICE for the purpose specified in
paragraph (2)(i) below for a maximum of 100 hours per calendar year. Any operation for non-
emergency situations as allowed by paragraph

(3) below counts as part of the 100 hours per calendar year allowed by this paragraph (2).

(i) Emergency stationary ICE may be operated for maintenance checks and readiness
testing, provided that the tests are recommended by federal, state or local government,
the manufacturer, the vendor, the regional transmission organization or equivalent
balancing authority and transmission operator, or the insurance company associated with
the engine. The permittee may petition the Director for approval of additional hours to be
used for maintenance checks and readiness testing, but a petition is not required if the
permittee maintains records indicating that federal, state, or local standards require
maintenance and testing of emergency ICE beyond 100 hours per calendar year.

(4) Emergency stationary ICE may be operated for up to 50 hours per calendar year in non-
emergency situations. The 50 hours of operation in non-emergency situations are counted as
part of the 100 hours per calendar year for maintenance and testing in paragraph (2) above.
Except as provided in paragraph (3)(i) below, the 50 hours per calendar year for non-emergency
situations cannot be used for peak shaving or non-emergency demand response, or to generate
income for a facility to an electric grid or otherwise supply power as part of a financial
arrangement with another entity.

(i) The 50 hours per calendar year for non-emergency situations can be used to supply
power as part of a financial arrangement with another entity if all of the following
conditions are met:

(a) The engine is dispatched by the local balancing authority or local
transmission and distribution system operator;

(b) The dispatch is intended to mitigate local transmission and/or distribution
limitations so as to avert potential voltage collapse or line overloads that could
lead to the interruption of power supply in a local area or region.
100

(c) The dispatch follows reliability, emergency operation or similar protocols
that follow specific NERC, regional, state, public utility commission or local
standards or guidelines.

(d) The power is provided only to the facility itself or to support the local
transmission and distribution system.

(e) The owner or operator identifies and records the entity that dispatches the
engine and the specific NERC, regional, state, public utility commission or
local standards or guidelines that are being followed for dispatching the engine.
The local balancing authority or local transmission and distribution system
operator may keep these records on behalf of the engine owner or operator.

(B) The permittee shall comply with the applicable requirements of 40 CFR Part 60, Subpart A, as
identified in Table 3 of 40 CFR Part 60, Subpart JJJJ. [Authority: 40 CFR Part 60, Subpart JJJJ; Origin:
40 CFR 60.4243(d)(1)-(3) and 40 CFR 60.4246]

II.B.9.d.1 Monitoring:

Maintenance records required under Recordkeeping below will serve as monitoring.

II.B.9.d.2 Recordkeeping:

(A) The permittee shall keep a maintenance plan and records of conducted maintenance and
must, to the extent practicable, maintain and operate the engine in a manner consistent with
good air pollution control practice for minimizing emissions. [40 CFR Part 60.4243(c)]

(B) The permittee shall keep records of the information in (1) through (3) below:

(1) All notifications submitted to comply with this Condition and all documentation
supporting any notification.

(2) Maintenance conducted on the engine.

(3) Documentation that the engine meets the emission standards. [40 CFR Part
60.4245 (a)(1), (2), & (4)]

(C) Results of monitoring shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.9.d.3 Reporting:

There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: In compliance – Generator maintenance is conducted in-house and is tracked on the FAM
database. See status of condition II.B.9.a.

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II.B.10 Conditions on Diesel Engine for Water Pump.

II.B.10.a Condition:

Visible emissions shall be no greater than 10 percent opacity.

[Authority granted under R307- 401-8; condition originated in DAQE-AN107250026A-16]

II.B.10.a.1 Monitoring:

If an affected emission unit is operated during a calendar quarter, an opacity observation of the
emission unit shall be performed in the quarter that the emission unit was operated. The opacity
observation can be conducted at anytime during the quarter. The opacity observation shall be
conducted by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9, while the emission unit is operating. If visible emissions other than condensed water
vapor are observed from the emission unit, an opacity determination of that emission unit shall
be performed by a certified observer within 24 hours of the initial visual emission observation.
The opacity determination shall be performed in accordance with 40 CFR 60, Appendix A,
Method 9.

II.B.10.a.2 Recordkeeping:

Results from opacity observations and all data required by 40 CFR 60, Appendix A, Method 9
shall be recorded and maintained in accordance with Provision I.S.1 of this permit

II.B.10.a.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – The quarterly water pump visual opacity observation (Method 9) records
were reviewed at time of the inspection. The last quarterly visual opacity observation was
conducted on December 30, 2024, and had an opacity of < 10 %.

II.B.10.b Condition:

The permittee shall comply with the following operating limitations:

(a) The permittee shall operate the affected emission unit according to the conditions described in
paragraphs (a)(1) through (a)(4).

(1) Any operation other than emergency operation, maintenance and testing, and operation in
non-emergency situations for 50 hours per calendar year, as permitted in (a)(4), is prohibited.

(2) There is no time limit for use during emergency situations.

(3) Operation for the purpose of maintenance checks and readiness testing is limited to 100
hours per calendar year, provided that the tests are recommended by Federal, State or local
government, the manufacturer, the vendor, the regional transmission organization or equivalent
balancing authority and transmission operator, or the insurance company associated with the
engine. A petition for approval of additional hours to be used for maintenance checks and
readiness testing is not required if the permittee maintains records indicating that Federal, State,
or local standards require maintenance and testing of emergency RICE beyond 100 hours per
102
calendar year.

(4) Operation in non-emergency situations is limited to 50 hours per calendar year, but those
50 hours are counted towards the 100 hours per calendar year provided for maintenance and
testing and shall meet the requirements in 40 CFR 63.6640(f)(4).

(b) The permittee shall meet the following requirements:

(1) Change oil and filter every 500 hours of operation or annually, whichever comes first;

(2) Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;

(3) Inspect all hoses and belts every 500 hours of operation or annually, whichever comes
first, and replace as necessary.

During periods of startup, the permittee shall minimize the engine’s time spent at idle and minimize the
engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the non-startup emission limitations apply.

(c) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.

(d) If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the work practice requirements on the required schedule, or if performing the
work practice on the required schedule would otherwise pose an unacceptable risk under Federal, State,
or local law, the work practice can be delayed until the emergency is over or the unacceptable risk under
Federal, State, or local law has abated. The work practice shall be performed as soon as practicable after
the emergency has ended or the unacceptable risk under Federal, State, or local law has abated. [40 CFR
63 Subpart ZZZZ Table 2c Footnote 1]

[Authority granted under 40 CFR 63 Subpart ZZZZ; Condition originated in 40 CFR 63.6595(a)(1), 40
CFR 63.6602, 40 CFR 63.6605(a), 40 CFR 63.6625(h), 40 CFR 63.6640(f), 40 CFR 63.6665, 40 CFR 63
Subpart ZZZZ Table 2c, 40 CFR 63 Subpart ZZZZ Table 8]

II.B.10.b.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed. [40 CFR
63.6625(f)]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee has the option of utilizing an oil analysis program in order to extend the specified
oil change requirement in accordance with 40 CFR 63.6625(i).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ.

103
II.B.10.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall keep records of the hours of operation of the engine that are recorded through
the non-resettable hour meter. The permittee shall document how many hours are spent for
emergency operation, including what classified the operation as emergency and how many hours
are spent for non-emergency operation. If the engines are used for demand response operation,
the permittee shall keep records of the notification of the emergency situation, and the time the
engine was operated as part of demand response. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that Federal, State, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per year. [40 CFR 63.6640(f)(3)]

The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.10.b.3 Reporting:

The permittee shall report any failure to perform the work practice on the schedule required and
the Federal, State or local law under which the risk was deemed unacceptable. [40 CFR 63
Subpart ZZZZ Table 2c Footnote 1]

The permittee shall report each instance in which it did not meet an applicable operating
limitation in 40 CFR 63 Subpart ZZZZ Table 2c. These instances are deviations from the
operating limitations. These deviations shall be reported according to the requirements in 40
CFR 63.6650. [40 CFR 63.6640(b)]

The permittee shall submit each report in 40 CFR 63 Subpart ZZZZ Table 7 as applicable. [40
CFR 63.6650(a)]

If there are no deviations from any applicable operating limitations, the permittee shall submit a
compliance report semiannually for affected emission units according to the requirements of 40
CFR 63.6650(b)(1)-(5) that contains the information required in 40 CFR 63.6650(c)(1)-(3) and a
statement that there were no deviations from the operating limitations during the reporting
period. [40 CFR 63 Subpart ZZZZ Table 7.1.a]

104
If a deviation from any operating limitation occurs during the reporting period, the permittee
shall submit a compliance report semiannually according to the requirements of 40 CFR
63.6650(b), (f) that contains the information required in 40 CFR 63.6650(c)(1)-(3), (d). [40 CFR
63 Subpart ZZZZ Table 7.1.b]

If a malfunction occurs during the reporting period, the permittee shall submit a compliance
report semiannually according to the requirements of 40 CFR 63.6650(b) that contains the
information required in 40 CFR 63.6650(c)(1)-(4). [40 CFR 63 Subpart ZZZZ Table 7.1.c]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63 Subpart ZZZZ Table 8. [63.6665]

The permittee shall also report each instance in which it did not meet the applicable requirements
in Table 8. [40 CFR 63.6640(e)]

There are no additional reporting requirements for this provision except those specified in
Section I of this permit.

Status: In compliance – The water pump has a non-resettable hour meter. It is maintenance checked
10-15 minutes per week. Maintenance is conducted in-house. Maintenance and hours of operation
are tracked in the FAM database. It should be noted that the water pump has only been operated
for maintenance in 2024.

II.B.10.c Condition:

The permittee shall operate and maintain the affected emissions unit, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with safety and good air pollution
control practices for minimizing emissions. The general duty to minimize emissions does not require the
permittee to make any further efforts to reduce emissions if levels required by this standard have been
achieved. Determination of whether such operation and maintenance procedures are being used will be
based on information available to the Director which may include, but is not limited to, monitoring
results, review of operation and maintenance procedures, review of operation and maintenance records,
and inspection of the source. [Authority granted under 40 CFR 63 Subpart ZZZZ; Condition originated
40 CFR 63.6595(a)(1), 40 CFR 63.6605(b)]

II.B.10.c.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.10.c.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

105
II.B.10.c.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: In compliance – See status of condition II.B.10.b.

II.B.10.d Condition:

Emergency generators shall be used for electricity producing operation only during the periods when
electric power from the public utilities is interrupted or during maintenance.

[Authority granted under R307-401-8(1); condition originated in DAQE-AN107250026A-16]

II.B.10.d.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.10.d.2 Recordkeeping:

Records of hours of operation for maintenance firing purposes and emergency use shall be kept
on a monthly basis for each affected emission unit. Results of monitoring shall be maintained as
described in Provision I.S.1 of this permit.

II.B.10.d.3 Reporting:

There are no reporting requirements for this provision except those specified in Section I of this
permit.

Status: Repeat of condition II.B.9.a.

II.C Emissions Trading.

Not applicable to this source.

II.D Alternative Operating Scenarios.

Not applicable to this source.

II.E Source-specific Definitions.

Not applicable to this source.

SECTION III: PERMIT SHIELD

A permit shield was not granted for any specific requirements.

106
SECTION IV: ACID RAIN PROVISIONS

IV.A This source is not subject to Title IV.

EMISSIONS INVENTORY: The 2023 triannual emission inventory was submitted on April 10, 2024.

The 2026 triannual emission inventory is due by April 15, 2027. The
facility is considered to be in an Attainment Area for Ozone.

PREVIOUS ENFORCEMENT
ACTIONS: None in the last five years.

COMPLIANCE STATUS &
RECOMMENDATIONS: In compliance with the conditions of the current Title V Operating
Permit 4500048004, dated November 23, 2021, and revised November
23, 2021, at time of the inspection.

HPV STATUS: N/A

COMPLIANCE
ASSISTANCE: 1) Discussed providing only two six-month monitoring reports for the
annual compliance certification report period instead of three. See status
of condition I.S.2 and attached Request to Modify Timeframe for
Semi-Annual Monitoring Report correspondence.

107
RECOMMENDATION FOR
NEXT INSPECTION: Facility is shut down every six months to conduct maintenance. Fridays
are considered to be work days. Inspect as usual.

ATTACHMENT: VEO Form
Request to Modify Timeframe for Semi-Annual Monitoring Report
Correspondence.

Joe Rockwell <[e-mail]>
Request to Modify Timeframes for Semi-Annual Monitoring Reports to Coincide with
Annual Air Compliance Certification
2 messages
Banks, Kenneth <[e-mail]>Mon, Dec 16, 2024 at 3:50 PM
To: Joe Rockwell <[e-mail]>
Cc: AG Compliance <[e-mail]>
Good afternoon Mr. Rockwell,

Thank you for reaching out to me this afternoon regarding the air reporting Clean Harbors Aragonite (CHA) has been
performing. To follow up on our earlier conversation, here are the items I propose to make this review of this paperwork a
bit more streamlined:
Continue to keep the Annual Air Compliance Certification as 9/22 of each calendar year
Update the Semi-Annual Monitoring, as well as the Semi-Annual Subpart V and DD Reports to match the Annual
Air Compliance Certification Timeline
To do this, I would provide Semi-Annual Reports for the above in March. The time-window for the monitoring
period would be from 9/23/2024 – 3/22/2025. This would cover both the upcoming months (December-
March), as well as include some previous months already reports (September-November).
Once the September semi-annual reporting is submitted (3/23/2025 – 9/22/2025), everything would be on
the same timelines, without any missing months.

Please let me know if the information above will work for you, and if you have any questions.

Thanks, and have a great day.

Safety Starts with Me: Live It 3-6-5
_________________________________
Kenneth Banks
Senior Environmental Compliance Manager
Clean Harbors Aragonite, LLC
(o) 435.884.8233
(c) 435.579.5193
[e-mail]
www.cleanharbors.com

12/16/24, 6:36 PM State of Utah Mail - Request to Modify Timeframes for Semi-Annual Monitoring Reports to Coincide with Annual Air Compliance C…
https://mail.google.com/mail/u/0/?ik=391b7b8965&view=pt&search=all&permthid=thread-f:1818639150539291954&simpl=msg-f:18186391505392919…1/2
Joe Rockwell <[e-mail]>Mon, Dec 16, 2024 at 6:36 PM
To: "Banks, Kenneth" <[e-mail]>
Hi Ken -
Sounds good to me.
Let's see how it works out.
Thank you for your cooperation.
Joe Rockwell | Environmental Scientist
Phone: [phone]

195 North 1950 West, Salt Lake City, UT 84116

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA requirements.
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12/16/24, 6:36 PM State of Utah Mail - Request to Modify Timeframes for Semi-Annual Monitoring Reports to Coincide with Annual Air Compliance C…
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