On October 28, 2024, EPA issued an Administrative Compliance Order on Consent to Sims ARG, Inc. ( Respondent ), a scrap metal shredding and recycling facility located at 3000 Vera Street, Baltimore, MD 21226 ( Facility ). Respondent acquired the Facility from Baltimore Scrap through an asset purchase. EPA's investigation determined that the Facility has a potential to emit more than 25 tons per year of volatile organic compounds, and that the Respondent was operating the Facility without a Title V Operating Permit or a Synthetic Minor Operating Permit in the alternative. Respondent's failure to comply with Section 502 of the Clean Air Act ( CAA ), 42 U.S.C. 7661(a), and Maryland's Part 70 Permit Program found at COMAR 26.11.03, constituted a violation of the CAA subjecting them to enforcement pursuant to Section 113 of the CAA, 42 U.S.C. 7413. Under the terms of an Administrative Compliance Order on Consent issued pursuant to Section 113(a) of the CAA, 42 U.S.C. 7413(a), Respondent is required to either (1) apply for and obtain a Title V Operating Permit in accordance with Section 502 of the CAA, 42 U.S.C. 7661(a) and Maryland's Part 70 Permit Program regulations found at COMAR 26.11.03; or (2) apply for and obtain a Synthetic Minor Operating Permit in accordance with enforceable conditions on its Facility operations. Those enforceable conditions include a maximum annual shredder processing rate of no more than 225,000 net tons of total recyclable material feed to the s