The regulations for stationary sources of fugitive air emissions does not include industrial Open Burning as regulated under RCRA Subpart X permits. The Radford Army Ammunition Plant currently operates an Open Burning Ground with a Title V permit that allows for 8,000 pounds of munitions constituents to be burned per day. This includes the open burning of chromium, barium, aluminum, perchlorate and other toxins without any pollution control devices nor ambient air quality monitoring. Will VA DEQ consider including all facilities conduction Open Burning under a RCRA Subpart X permit in these more stringent air pollution control regulations? If not, why is an exception being granted for such a significant source of toxic air pollution? The record shows that over 440,000 pounds of waste were burned to the open air in 2011 alone. How is VA DEQ addressing this major point source of air pollution in the New River Valley under Title V provisions?