On September 22, 2016, EPA alleged that ICS exceeded a Title V permit provision that required ICS to capture and contain all emissions from its drum reclamation furnace. The ACO memorializes changes that ICS has made to the furnace. Specifically, ICS has increased the speed of the fan that draws air into the furnace through its natural draft openings. Further, ICS replaced a set of steam nozzles that were 45 inches from the furnace's drum conveyor outlet with a set of steam nozzles that is 210 inches from the furnace's drum conveyor outlet. EPA and ICS believe that moving the replacement set of nozzles will assist in the capture and containment of particulate matter. ICS is not subject to a numerical emission standard for the furnace's drum conveyor outlet.