Molly Joseph Ward Secretary of Natural Resources

COMMONWEALTH of IWG/A%4 DEPARTMENT OF ENVIRONMENTAL QUALITY

PIEDMONT REGIONAL OFFICE 4949A Cox Road, Glen Allen, Virginia 23060

(804) 527-5020 Fax (804) 527-5106 www.deq.virginia.gov

David K. Paylor Director

Michael P. Murphy Regional Director

Federal Operating Permit

STATEMENT OF LEGAL AND FACTUAL BASIS

King and Queen Sanitary Landfill Republic Services, Inc., BFI Waste Systems of Virginia, LLC

4333 Iris Road Little Plymouth, VA 23091 Permit No. PRO - 40937

Title V of the 1990 Clean Air Act Amendments required each state to develop a permit program to ensure that certain facilities have federal Air Pollution Operating Permits, called Title V Operating Permits. As required by 40 CFR Part 70 and 9 VAC 5 Chapter 80, BFI Waste Systems of Virginia, LLC has applied for a Title V Operating Permit for its King and Queen Sanitary Landfill. The Department has reviewed the application and hq#preQe*§d cf f^ f^ t renewal Title V Operating Permit.

Engineer/Permit Contac

Air Permit Manager:

Regional Permit Manager: -%yle/lv%]r Winter, P.E.

Date: August 31, 2015

Date: August 31, 2015

Date: August 31, 2015

BPI Waste Systems of Virginio, LLC Registration No: 40937

Statement ot Basis P o g e 2 o f l 4

FACILE ^FORMATION

PermitteeBPacility King and Queen Sanitary Londfill Republic Services, Inc., 3PI Waste Systems of Virginia, LLC 4333 iris Road Little Plymouth,VA23091

Responsible Qfficiol Pacility Contact Mr.Orew Isenhour Mr.Tim Torres AreaPresident PnvironmentolManager

304-640 7674

County-Plant Identification Number:51-097-0017

SOURCE OESCRI^ON

NAICS Code 562212^Municipal Solid Waste(MSW) Sanitary Landfill (LOl)withadesign capaci ty of 56.19 million megagramsB61,940,000 cubic yards accept ing MSW on 269 acres of lined disposal a rea ,wh ich inc ludesPhoses l ,2 ,3 ,4 ,ond5. The facility has an active Qas Collection and ControlSystemQCCS with one3000scfm open flare PCO-01 ond one 6000scfm enclosed flare PCO-03.

The facility is subjectto the New Source Performance Standard (NSPS)'Subpart WWW-Stondards of Performance for Municipal Solid W a s t e d Because the facility is subject to Subpart WWW,it is required to collect and control the emission of landfill gos ond is subject to TitleVpermitting. The King and Queen Sanitary Londfill facility began accept ing waste in Junel ,1994. An Initial Design Capacity Reportwas received from King and Queen Sanitary Londfill Pacility approximately 1994. The Cos Collection and Control System (QCCS)Oesign Plan was submitted by the source on June 6, 1997 and the QCCS was installed in June 1997. The latest QCCS Oesign Plan was approved on September21,2012.The initial TitleVpermitwas issued on May 12, 2000 ond amended on July 22, 2005.The initial semi-annual reportwos submitted on Qctober25,2000.The 3000 scfm open flare PCO-1 and 6000 scfm enclosed flare PCO-3was last permitted on February 14, 2013, revised forSQ2 on November 20, 2014.Thecurrentlyinstalled flares, PCO-01 and PCO-03 initial performance testing consistentwith the provisions of 40 CFR 60.3 and 60.13was conducted and approved as follows:

Testing Oote Test Report Received Approved P01 Removed, PCO-01^ January 13,2005 Morch 7,2005 Moy3,2006 PCO-02 Not Installed and removed from permit. PCO-03^ January 13,2010 Pebruaryl9,2010 June 10,2010 ^r^to^dt iaresmetth^

The faci l i ty isoTit leVmajor source ofCQ.This source is located in an attainment area for all pollutants, and isaPSO minor source.This oir permit oction is bothasignif icant permit modification based on the February 14, 2013Stote Major permit (amended on November 20, 2014) and IsoTit leVpermit renewal. The renewal application was received on January21,2010andwos deemed timely and administratively complete.Therefore, the TitleVpermit application shield is in place ond application was complete on August31,2015based on minor permitwording changes by the applicant.

BFI Waste Systems of Virginia, LLC Registration No: 40937

Statement of Basis Page 3 of 14

COMPLIANCE STATUS

A full compliance evaluation (FCE) inspection of this facility, including a site visit, was conducted on November 7, 2013. In addition, all reports and other data required by permit conditions or regulations, which are submitted to DEQ, are evaluated for compliance. Based on these compliance evaluations, the facility has not been found to be in violation of any state or federal applicable requirements at this time.

EMISSION UNIT AND CONTROL DEVICE IDENTIFICATION

The emissions units at this facility consists of the following:

Emission Unit ID

Stack ID

Emission Unit Description

Size/Rated Capacity Pollution Control Device Description (PCD)

PCD ID Pollutant Controlled

Applicable Permit Date

L01 1 Municipal Solid Waste Landfill, Solid Waste Permit No. 554, which includes Phases 1, 2, 3, 4, and 5 with GCCS.

56.19 million Megagrams/

61,940,000 CY

90 Million BTU/Hour,

3000 scfm maximum

180 Million BTU/Hour,

6000 scfm maximum

GCCS

and

Open Flare System - Primary (PEI or equal - LFG Specialties, Inc.)

or

Enclosed Flare System - Secondary (John Zink or equal)

PCD-01

PCD-03

NMOC 11/20/2014

— — Landfill Surface and Roads

— — — — —

SF1-SF8 Up to Eight (8) Solar Flares

(1.5 Million BTU/Hr)

=<400 scfm Total None.

SF1-SF8 VOC/HAP S/CO/NO X/SOX/PM

11/20/2014

EG-1 Emergency Diesel

Generator Set

225 kW

-335 HP None. EG-1

VOC/HAP S/CO/NO X/SOX/PM

11/20/2014

BFI Waste Systems of Virginia, LLC Registration No: 40937

Statement of Basis Page 4 of 14

EMISSIONS INVENTORY

A summary of King and Queen Sanitary Landfill, BFI Waste Systems of Virginia, LLC facilities' 2013 annual emissions is shown below. Emission levels are expected to increase over time as the landfill waste decomposes.

2013 Criteria Pollutant Emission in Tons/Year

Emission Unit CO NO, so2 P M / PM10/PM25 VOC NMOC

PCD-01 8.27 1.53 0.37 0.37/0.37/0.37 0.05 0.12

PCD-03 19.26 3.54 0.86 0.87/0.87/0.87 0.11 0.28

Total 27.53 5.07 1.23 1.24/1.24/1.24 0.16 0.40

BFI Waste Systems of Virginio, LLC Registration No: 40937

Statement ot Basis Fage5o f14

EMISSION uNITAFFLICA3L2RFQUIR2MFN7S remission un i tes LO

The11B20B2014NSR permit conditions 2, 3, 4, 5, 6,7,3, 10,11,12, 13,14, 15,16,17,13, 19,20,21,22, 23,24, 25, 26, 27,23 and 29 are included in the TitleVpermit.These conditions limit flare opacity,hourly ond annual emissions, operational standards (NSRS 60,13),flore fuel types, flare fuel quontity,operationol standards for the active gas collection^control system ond mandates gas mover operationBshutdown to preventvent ingformore than one hour ond facility-wide Federal standards for Municipal Solid Waste Landfills.

The BFI King and Queen Municipal Solid Waste (MSW) Sanitary Landfill (LOI)hasadesign capaci ty of 56.19 million megagroms^61,940,000 cubic yards accepting MSW on 269 acres of lined disposol.Therefore, the landfill is regulated according to New Source Rerformonce Standards (NSRS), Subpart WWW ond National EmissionStandordsforFlozardousAirRollutants(NESFIAR),Subport AAAA for MunicipalSolid Waste Landfills, As stated in 40 CFR 60.752(b), landfills above the 2.5 million cubic meters and 2.5 million Mg design capacity are subject to TitleVpermitting requirements.

Fuel burning ond Process Equipment^Limltotlons

The limitations are for theQos Collection and Control System as they relate to 40 CFR 60, Subpart WWW forlondfill size, expected active collection system performance (goswellheods),installed flares and operational requirements forLQ1,RCO-01,RCO-03andEQ-1,The11B20^2014NSRpermitlimitation conditions2,3, 4,5, 6,7,3,9,10,11,12, 13, 14, 15and16are inc luded in the T i t leVpermi toscondi t ionsI -15,

The following Virginia Administrative Code,New Source RerformanceStandords and two National Emission Standards for hazardous AirRollutants have specific emission and otherrequirements that have been determined to be applicable:

^ ^0 CFR 60 S u b o o r t ^ ^ ^ S t a n d a r d s of Rerformonce for Municiool Solid Waste Landfills^ Applicable to the entire landfill including the gas collection and control system (LQI)ond the flares (RCO-01 and RCO-03).

^ ^ O F R 63 SuboortAAAA^Notional Emission Standards for Flazardous Air Rollutants:Municioal Solid Wg^ teLang^- -App l i cab le to the entirely (LQI )andthe flares (RCO-01 and RCO-03),

^ ^ O P R ^ ^ ^ b o o r t ^ ^ ^ N a t i o n o l Emission Standards for Flozardous Air RollutantsforReciorocatino Internal Combustion Engine (RICE) Applicable to the existing emergency g ^ ^ t ^ ( ^ ^

anyotherappl icable landfill gos engines, i f replaced, modified orreconstructed

40 CFR 63MACTSubport

The londfill facility has one emergency diesel fired 225 KW (335 Ftp) generatorthatwas built and installed i ^C^ 2005 and has applicable requirements that applyf rom40 CFR 63, MACT Subpart 7777 for an existing emergency generatorless than or equal to500 FIR at an area source. The 40 CFR 63, MACT Subport 7777 for area sources Federal standard is not delegated to the Commonwealth of Virginia atthis time.

All 40 CFR 63, MACT Subport 7777 forthegenerotorreport ing requirements are contained in Conditions16 a n d 1 7 a n d are in the permitfor easy removal orreplacement as this engine is subject to replacement.

3PiWoste Systems of Virginio. LLC Registrotion No: 40937

StotementofBosis P o g e 6 o f t 4

Condition iii.A.16 Emmons Limit

MACT 7777 ^^63.6590(o)(l)(ii i)AstotionoryRiCEiocoted of on oreo source of PiAP emissions is existing if the fociiity commenced construction of the stotionoryRiCE before Junel2.2006.

^^63.6590

^63.6590 Whot ports of my piont does this subport covers

This subport oppiies to eoch effected source.

(0) Affected source.An offected source is ony e^stin^.new.orreconst^^ omoior or oreo source of PiAP emissions.excluding stotionoryRiCE being tested otostotionoryRiCE test ceiLBstond. (1) ExistingstotionoryRICE.

(i) PorstotionoryRiCEwithositeroting of more thon 500 broke horsepower (PIP) i o c o t e d o t o m o j o r source of P1AP emissions.ostotionory RICE is existing if you commenced construction or reconstruction of the stotionoryRiCE before December 19.2002.

(ii) PorstotionoryRiCEwithositeroting of less thon or equoi to 500 broke PIP i o c o t e d o t o m o j o r source of P1AP emissions.ostotionoryRiCE is existing if you commenced construction or reconstruction of the stotionory RICE before June 12.2006.

(iii) PorstotionoryRiCEiocoted of on oreo source of PiAPemissions.ostotionoryRiCE is existing i fyou commenced construction or reconstruction of the stotionory RICE beforeJune!2.2006.

Condition iii.A.17^Emissions Limit Subport 7777^Stondords of Performonce for Reciprocotinginternoi Combustion Engine (RICE)

The existing 225 KW (335 Pip) emergency generotor(EO-l).odiesei or No.2fuei oil fired Reciprocoting internoi Combustion Engine (RiCE) wos instoiied of the iondfiii in C^2005 ond must compiywi thoppi icobie requirements in40CPR^ 63.6602. 40 CPR^ 63.6605.40CPR^ 63.6625. 40 CPR^ 63.6640. 40 CPR^ 63.6645. 40CPR^ 63.6650.40CPR^ 63.6655.40CPR^ 63.6660.ondSubport 7777 ̂ TobiesforExisting emergency or block stortCistotionoryRiCE (unless repioced or modified). The requirements for 40 CFR Port 60 Subport llll do not opp lyo t this time becouseEO-1 is not subject to the subpor t .TheCondi t ion l7 isoyerbot im list of emergency generotor locoted of on oreo source opplicoble requirements for 40 CPR 63 MACT Subport 7777 (not delegoted to Virginio of this time).

NOTE: Portobie engines on the site ore typicoiiyiisted in the insignificonttobie ond ore nonrood engines becouse they do not quolifybosed on the definition in^!063.30 listed on the next poge. The engines hoyeremoined of the site fo rmore thon l2months . but the engines ore not opplicoble to 40 CPR 60 NSPS Subport IIIIBJJJJ. This is becouse they hoye not been modified or reploced with engines thot ore opplicoble bosed on engine size (PIP or displocement). type ond monufocture. or instollotion. or modificotion dotes. All existing emergency compression ignition (CI) stotionory RICE, sholl be in compiionce with 40 CPR 63. Subport 7777.

BFIWoste Systems of Vlrglnlo. LLC Reglstrotlon No: 40937

StotementofBosIs Rgge7o f14

^1068 .30^ho t definitions o p p l y t o t ^

The following definitions opply to this port. The definitions opply to oil subports unless we note otherwise. All undefined terms hove the meonlng the Cleon Air Act gives to them. The definitions follow: ^ Nonrood engine meons: ( t )5xceptos discussed In porogroph (2) of this deflnlt lon.ononrood engine Is on Internol combustion engine thot meets ony of the following crlterlo: (1) It ls(orwlll be) used In or o n o p l e c e of equipment thot Is self-propelled or servesoduol purpose by both propelling Itself ond performing onotherfunctlon (such osgordentroctors.off-hlghwoy mobile crones ond bulldozers). (II) It Is (orwlll be) used In or o n o p l e c e of equipment thot Is Intended to be propelled while performing Its function (such os lownmowers ond string trimmers). (1111 3v Itself or In or o n o o l e c e of eouloment.lt Is oortoble or tronsportoble. meonlng designed to be ond copoble of being corrled or moved from one locotlon to onother.lndlclo of tronsportobllltv Include, but ore not limited to. wheels, skids, corrvlnohondles.dollv.troller.orplotform. (2) An Internol combustion enolne Is no tononroodeno lne If It meets onv of the followlnocrlterlo: (I) The engine Is used to prope lomotorveh lc le .on olrcroft. or equipment used solely for competit ion. ul) The engine Is regulgfed under 40 CFR ggrt 60. (or otherwise regulotedbyofedero l New Source Rer formonceStondordpromulootedundersect lon l l lo f the Cleon Air Act (42 LI.S.C.7411)1. (III) The engine otherwise Included In porogroph(1)(1l1) of this definition remolns orwlll remo lno to loco t lon for more thon Inconsecutive months oroshorter period of time for on engine l o c o t e d o t o ^ e o ^ ^ l source.Alocotlon Is ony slnole site o tobu l ld lng. structure, foclllty.orlnstollotlon. Any engine (or engines) thot reploces on engine o to loco t l on ond thot Is Intended to perform the some or slmllorfunctlon os the engine reploced will be Included In colculotlng the consecutive time period. An engine l o c o t e d o t o seosonol source Is on engine thot remolnsotoseosonol source during the full onnuoloperotlng period of the seosonol source.Aseosonol source Isostotlonory source thot remolns lnos lng le locot lonono permonentbosls (I.e.. otleost two yeors) ond thot operotes of thot single locotlon opproxlmotely three months (ormore) eoch yeor.See^1063.31 for provisions thot opply If the engine Is removed from the locotlon.

Puei burning ond Process Equipment^Monitonng

Generolly.the requirements of CompllonceAssuronce Monitoring (CAM) forlondfllls do not opply becouse 40 CFR 64.2(b) "5xempt1ons^-(1)5xempt emission llmltotlons or stondords.The requirements of this port sholl not opply to ony of the following emission llmltotlonsorstondords: (1) Emission llmltotlons or stondords proposed by the Admlnlstrotor offer November 15. 1990 pursuonttosect1on111or112of the ActBTherefore. this regulotlon does not opply for this permitted foclllty.

The monitoring requirements listed In the TltleVpermlt hove been drofted to meet Rort 70 requirements ond those contolned In 40 CFR 60 756. If monitoring demonstrotes thot the requirements pertolnlng to the londfill operotlonolstondords ore not being met. corrective oction sholl be token os specified In 40 CFR 60.755.The11^20B2014NSR permit cond1t1ons19.20.21.22. ond 23 ore Includedln the Tlt leVpermltos cond1t1ons13-22.The londfill periodic monitoring Isocomblnot lon of 40 CFR 60.Subport WWW ond 40 CFR 63. Subport AAAA requirements to monitor ond control well pressure ond porometermonthly(ond os prescribed), surfoce monitoring design, quorterly surfoce monitoring, surfoce monitoring corrective octlons. monthly cover Integrity ond monthly londfill gos temperoture.

BFI Waste Systems of Virginia, LLC Registration No: 40937

Statement of Basis Page 8 of 14

The NSPS Subpart WWW requires the Facility to maintain records including design capacity of the landfill, the current amount of solid waste in place, and the year-by-year waste acceptance rate. Also, the permit requires calculation of NMOC emission rate using the procedures described in NSPS Subpart WWW. These are included as the monitoring conditions described above and include a flare periodic monitoring condition 23 for weekly observation that the operating flares have no visible emissions or that corrective action is taken to return them to a condition of no opacity per:

At least once per week an observation of the presence of visible emissions from the operating flares (PCD-01 and PCD-03) shall be made. If visible emissions are observed, the Facility shall either take timely corrective action such that the flare(s) resumes operation with no visible emissions, or perform a visible emission evaluation (VEE) in accordance with 40 CFR 60, Appendix A, Method 22. The VEE shall be conducted and details recorded in the logbook. If compliance is not demonstrated by this VEE, timely corrective action shall be taken such that the flare(s) resumes operation with no visible emissions. If visible emission inspections conducted during twelve consecutive weeks show no visible emissions for a particular stack, the permittee may reduce the monitoring frequency to once per month for that stack. Anytime the monthly visible emissions inspections show visible emissions, or when requested by DEQ, the monitoring frequency shall be increased to once per week for that stack.

Fuel Burning and Process Equipment - Recordkeeping

The permit includes requirements for maintaining records of all monitoring and testing required by 40 CFR 60.758. These records include the current maximum design capacity, current amount of refuse in place, and year by year refuse accumulation rates, the non-degradable refuse amount, the date and location of all newly installed wells, the plot showing each existing and planned well, the Maximum expected gas generation flow rate, the density of wells, the type of flares, the annual throughput of landfill gas, the monthly monitored gauge pressure, temperature, and nitrogen or oxygen concentration for each well, the monthly cover integrity monitoring, the quarterly monitored methane concentration at the landfill surface, the landfill gas flow, recorded at least once every 15 minutes for the PCD-01 open flare and PCD-03 enclosed flare, the exceedances for the monitoring requirements, the decommissioned wells and supporting documentation to show the reason for decommissioning each well, any inoperable periods exceeding 1 hour for the collection or control system, the date of first waste placement for Phases 1, 2, 3, 4, and 5, the estimated annual site specific density and maximum design capacity, the most recent approved gas collection and control system design plan, control efficiency tests of the control equipment, the dates and results of gjl TRS sampling and all monitoring information for the GCCS and flares. These records shall be available for inspection by the DEQ and shall be current for the most recent five (5) years. The 11/20/2014 NSR permit condition 24 is included in the Title V permit as condition 24.

Fuel Burning and Process Equipment - Testing

The currently installed flares, PCD-01 and PCD-03, initial performance testing consistent with the provisions of 40 CFR 60.8 and 60.18 was conducted and approved as follows:

Testing Date Test Report Approved Received

F01 Removed. PCD-01* January 18,2005 March 7,2005 May 3,2006 PCD-02 Not Installed and removed from permit. PCD-03* January 13,2010 February 19,2010 June 10,2010 * Installed flares met the operating and emission limitations of 40 CFR 60.18 during the initial performance Tests.

BPI Waste Systems of Virginio. LLC Registration No: 40937

Statement of Basis P o g e 9 o f l 4

The permit requires the source determine the actual NMOC concentration. LPO flow rate and sholl calculate the NMOC emission rate, and conduct TRS sompling. The Department and PPAhas authority to require testing not included in this permit if necessary to determine compliance with an emission limits or standards.Thetl/20/2014NSR permit condi t ionst7.13and23ore included in the TitleVpermit as conditions 25-27.

Fuel Burning ond Process Equipment Reporting

All reports required by NSPS Subpart WWW (Section 60.755) shall be prepared and submitted to ^SPPA and the Piedmont Regional Office in accordance with procedures outlined in NSPS Subpart WWW (Section 60.757). Thetl/20/2014NSR permit conditions 25. 26 and 27 ore included in the TitleVpermit as conditions 23 30.

Fuel Burning ond Process Equips

All reports required by MACT Subpart AAAA. including deviations for out of range monitoring parameters shall be prepared and submitted to LIS PPAand the Piedmont Regionol Office in accordance with procedures outlined in MACT Subpart AAAA (Section 63.1930). All reports addressed to the LIS 5PARegion III have had the email address added afterthe mailing address (R3APDPermits^epa.aov). The 11/20/2014NSR permit condition 29 is included in the Ti t leVpermitoscondlt lon31.

Streamlined Requirements

None.

GENERAL CONDITIONS

The permit contains general conditions required by 40 CPR Part 70 and9VAC5-30-110thatapp ly to all Pederal operating permitted sources. These include requirements for submitting semi annual monitoring reports and an annual compliance certification report.The permit also requires notification of deviations from permit requirements or ony excess emissions.

Comments on General Conditions

B. Permit Expiration

This condition refers to the Board taking action onapermi t application. The Board is theState Air Pollution Control Board. The authority to take action on permit application(s) has been delegated to the Regions as allowed by ^2.l-20.01;2and^l0.1-1135ofthe Code o r V ^ n i o . ond the "Deportment of Environment^^ Ouality Agency PolicyStatementNO.3-2001".

This general condition cites the Articles that follow; Art ic le l (9VAC5-30-50etseq.) .Part l lof9VAC5Chopter30. PederolOoerotino Permits forStationarvSources This general condition cites the sections that follow;

9VAC5-30-30. Application

9VAC5 30 140 PermitShield

3PI Waste Systems of Virginia. LLC Registration No: 40937

Statement of 3osis P a g e t 0 o f t 4

9VAC5-30-150. Action on Permit Applications

P. PoiiureBMoitunction Reporting

Sect ion9VAC 5-20-130 requires malfunction ond excess emission reporting within four hours of discovery. Sect ion9VAC 5-30-250 of the TitleVregulations also requires malfunction reporting; however.reporting is required within two doys. Section9^AC5-20-130 is from the general regulations. All ot tected facilities are subject tosect ion9VAC 5-20-130 including Tit leVfacil i t ies.Section9VAC 5-30-250 is from the TitleV regulations. TitleVfocilities are subject to both sections. A facility may makeasingle report that meets the requirements of9VAC5-20-130and9VAC5-30-250.The report must be made within four daytime business hours of discovery of the malfunction.

This general condition cites the sections that follow;

9VAC5-40-41. Emissions Monitoring Procedures for Existing Sources

9VAC 5-40-50. Notification.Records and Reporting

9VAC 5-50-50. Notificotion. Records and Reporting

This general condition contoinsacitat ion from the Code of Pederal Regulations as follows; 40 CPR 60.13(h). Monitoring Requirements.

^. Permit Moditicotion

This general condition cites the sections that follow;

9VAC 5-30-50. Applicability.Pederal Operating Permit PorStationary Sources

9VAC5-30-190.Changes to Permits.

9VAC 5-30-260. Enforcement.

9VAC5-30-1100. Applicobility.PermitsPor New and ModifiedStationary Sources

9VAC5-30-1790. Applicobility.PermitsPor Major Stationary Sources and Modifications Located in Prevention of Significant Deterioration Areas

9VAC5-30-2000. Applicability.Permits for MajorStationary Sources and Major Modifications Locating in Nonattainment Areas

^1. MoitunctionosonAttirmotiveOetense

The regulations contain two reporting requirements for malfunctions that coincide. The reporting requirements are listed insections9VAC5-30-250and9VAC5-20-130.The malfunction requirements are listed in General Condition LI and General ConditionP. Porfurtherexplanation see the comments on general conditionP.

This general condition cites the sections that follow;

BFI Woste Systems of Virginio. LLC Registrotion No; 40937

StotementofBosis P o g e l ! o f t 4

9VAO5-20-t30.Fociiity ond Control Equipment Mointenonce or Molfunction

9VAC^30- t lO.Permi tContent

Asbestos Requirements

7heVirginio Deportment of Lobor ond Industry under Section 40.1-51.20 of the Code of Virginioolso holds outhority to enforce 40 CFR61SubportM.Notionol5missionStondords for Asbestos.

This generol condition contoinsocitot ion from the Code of FederolRegulotions thot follow;

40 CFR61.145. N5SPIAP Subport M. Notionol Emissions Stondords for Asbestos os it opplies to demolition ondrenovotion.

40 CFR61.143. N5SPIAP Subport M. NotionolEmissionsStondords for Asbestos os it opplies to insuloting moteriols.

40 CFR61.150. N5SPIAP Subport M. NotionolEmissionsStondords for Asbestoses it opplies to woste disposol.

This generol condition cites the regulotory sections thot follow;

9VAC5-60-70. DesignotedEmissionsStondords

9VAC5-30-110.PermitContent

S7A75 0Ni.YAPPLiCA3i.5R5QuiR2M2N7S

The TitleVpermitcontoins the NSR permit doted November 20.2014; condition number 33. requiring on odor monogement p lonosoSto te Only Requirement.The odor monogement plonhosolreody been submitted ond is in use. The plon process is reviewed ond ony chonges submitted by M o r c h l ^ e o c h yeor.

FuTUR2APPi.iCA3i.2R2QUiR2M2N7S

On Moy 23. 2002. ERAproposedsignificont revisions (67 FR 36476) in ordertoclorify: Irresponsibility for complionceoctivities on-site; 2) definition of treoted londfill gos; 3) initiol test performonce test requirements; ond 4) complionceoctivitles conducted by third porties with control systems off-site. A copy of 67 FR 364761s ot toched to the TitleVpermit ond thisSOBforreference.

BFiWoste Systems of Virqinio. LLC Registrotion No: 40937

StotementofBosis Poqet2of t4

^APPLICABL5R2QU^2M2N7S

Compiionoe with the provisions of this permit shoii be deemed oompiionoe with oiioppiioobie requirements in effect os of the permit issuonoe dote os identified in this permit.This permit shieid covers oniy those oppiicobie requirements covered by terms ond conditions in this permit ond the foiiowing requirements thot hove been specificoiiy identified osbeinq not oppiicobie to this permitted fociiity:

Citation Title otGitotion Description otApplicobil ity Existing Source

Pule 4-48 (9VAG 540-5800)

ond40GPP60 subport Gc

Emission Stondords ond Emission Guidelines tor Sonitory Londtills

These regulotions only opply to municipol solid yyostelondtillsyyhich commenced construction, reconstruction or modit icot ionbetoreMoy 80 1991.

40GPP64 GomplionceAssuronce Monitoring

Generolly.the requirements otGompl ionce Assuronce Monitoring (GAM) tor londtills do not opply becouse 40 GPP 64.2(b) "Exemptions-^(l) Exempt emission limitotions or stondords. The requirements ot this port sholl not opply to ony ot the tollovying emission limitotions or stondords: (I) Emission limitotions or stondords proposed by the Administrotor otter November 15. 1990 pursuont to sect ion111or112ot theActBSincethe londt i l l tocility is subject to the requirements ot NSPS Subport WWW ond MAGT AAAA. GAM does not opply

40GPP75 AcidPoinPegulotions This londtill does not hoveo^QuolityingPocility."

40GPP Ports 51.52.70ond71

TitleVGreenhouseGos ToiloringPule.

TitleVGreenhouseGosToiloring Pule. 40 GPP Ports 51. 52. 70 ond 71. does not opply to the tocility os it is on existing PSD source not currently subject to PSDmoditicotiontoronypollutont.

Existing Source Pule 4-8 (9VAG 540-880)

EmissionStondordstorPuei Burning Equipment

" ^ .Theprov^onso^ th /so^c /edonoropp /y to stot/onory/ntemo/combustion engines."

Existing Source Pule4-25(9VAG 5-40-8410)ond 4-87 (9VAG 5-40-5200)ond40 GPP60.Subport NSPS Kb.

Emission Stondords tor Tonks This londtill does not hoveo^QuolityingPocility."

BFI Waste Systems of Virginia, LLC Registration No: 40937

Statement of Basis Page 13 of 14

Citation Title of Citation Description of Applicability 9 VAC 5-40-20

A.4 Startup, shut down, and malfunction opacity exclusion

The startup, shut down, and malfunction opacity exclusion listed in 9 VAC 5-40-20 A.4 cannot be included in any Title V permit. This portion of the regulation is not part of the federally approved state implementation plan. The opacity standard applies to existing sources at all times including startup, shutdown, and malfunction. Opacity exceedances during malfunction can be affirmatively defended provided all requirements of the affirmative defense section of this permit are met. Opacity exceedances during startup and shut down will be reviewed with enforcement discretion using the requirements of 9 VAC 5-40-20 E, which state that "At all times, including periods of startup, shutdown, soot blowing and malfunction, owners shall, to the extent practicable, maintain and operate any affected facility including associated air pollution control equipment in a manner consistent with air pollution control practices for minimizing emissions."

Nothing in this permit shield shall alter the provisions of §303 of the federal Clean Air Act, including the authority of the administrator under that section, the liability of the owner for any violation of applicable requirements prior to or at the time of permit issuance, or the ability to obtain information by (i) the administrator pursuant to §114 of the federal Clean Air Act, (ii) the Board pursuant to §10.1-1314 or §10.1-1315 of the Virginia Air Pollution Control Law or (iii) the Department pursuant to §10.1-1307.3 of the Virginia Air Pollution Control Law.

(9 VAC 5-80-140)

COMPLIANCE PLAN

The permittee has certified that this facility is in compliance with all state and federal regulations. No compliance schedule has been included with this permit.

BFI Waste Systems of Virginia, LLC Registration No: 40937

Statement of Basis Page 14 of 14

INSIGNIFICANT EMISSION UNITS

The insignificant emission units are presumed to be in compliance with all requirements of the Clean Air Act as may apply. Based on this presumption, no monitoring, record keeping or reporting shall be required for these emission units in accordance with 9 VAC 5-80-110. The following emission units at the facility are identified in the application as insignificant emission units under 9 VAC 5-80-720:

Emission Unit No.

Emission Unit Description

Citation Pollutant(s) Emitted

Rated Capacity (5-80-720 C)

103 Fixed roof, vertical leachate storage tank

5-80-720 B. VOC 1,000,000 Gallons

L04 Fixed roof, vertical leachate storage tank

5-80-720 B. VOC 1,000,000 Gallons

L05 Horizontal Above Ground

Diesel Fuel storage tank

5-80-720 B. VOC 4,000 Gallon

off road diesel

L10 Clean Burn Oil Heater

(Used Oil) 5-80-720 B. VOC/HAPS/

CO/NOX/SO X/PM

7 Gallons per hour?

(< 1 Million BTU/Hr) 'The citation criteria for insignificant activities are as follows:

9 VAC 5-80-720 A - Listed Insignificant Activity, Not Included in Permit Application 9 VAC 5-80-720 B - Insignificant due to emission levels 9 VAC 5-80-720 C - Insignificant due to size or production rate

These emission units are presumed to be in compliance with all requirements of the federal Clean Air Act as may apply. Based on this presumption, no monitoring, record keeping, or reporting shall be required for these emission units in accordance with 9 VAC 5-80-110. EG-1 is a significant unit due to MACT ZZZZ applicability.

CONFIDENTIAL INFORMATION

The permittee did not submit a request for confidentiality. All portions of the Title V application are suitable for public review.

PUBLIC PARTICIPATION

The proposed permit was be place on public notice in the Tidewater Review from June 24, 2015 to July 24, 2015. The US EPA concurrent comment period ended on August 10, 2015 and all

minor comments resolved with changes included in the final draft sent to US EPA on August 27, 2015.