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Mr. Himanshu Mehta <br /> 13 July 2007 <br /> Page 2 <br /> voluntarily-installed gas collection and control system (GCCS) that actively collects gas <br /> from Segment 1 , Segment 2, and the Infill area. <br /> Geosyntec understands that the IRCL facility is currently regulated under the New <br /> Source Performance Standards (HSPS) for MSW landfills as identified in Subpart <br /> WWW of 40 CFR, Part 60 (Subpart WWW). The NSPS states that MSW landfills that <br /> exceed certain size thresholds (waste-in-place of more than 2. 5 million Mg or 2 . 5 <br /> million m3) and emission thresholds (emissions of non-methane organic compounds <br /> (NMOC) of greater than 50 Mg/yr) are required to collect and control its landfill gas. <br /> Currently, the IRCL does not exceed the emission thresholds prescribed by NSPS, and <br /> results of Tier 2 sampling and testing conducted in December 2006 indicated that the <br /> projected NMOC emission rate through 2010 is below 50 Mg/yr. Therefore, the Class I <br /> Landfill will not be subject to the additional requirements of Subpart WWW to install <br /> and operate an active GCCS until that time or thereafter. <br /> In October 2006, the SWDD authorized Geosyntec under Task 5 (Technical Support) of <br /> Work Authorization No . 05 to evaluate the eligibility of the IRCL facility under the <br /> Chicago Climate Exchange (CCX) Landfill Methane credits program. Geosyntec is a <br /> current member of the U. S . Environmental Protection Agency (USEPA) Landfill <br /> Methane Outreach Program (LMOP), and also joined CCX as an Offset Aggregator on <br /> 22 January 2007. As part of the CCX offset project eligibility evaluation for IRCL, <br /> Geosyntec performed the following tasks : <br /> • evaluated the eligibility of the IRC Class I Landfill to become registered offset <br /> project as outlined in the CCX Rule Book based on the summary information <br /> provided by SWDD ; <br /> • introduced the IRC Class I Landfill project to CCX; <br /> • reviewed the IRC' s annual fuel consumption summary information provided by <br /> SWDD and performed a preliminary estimation of equivalent carbon dioxide <br /> (CO2) emissions ; <br /> • performed a preliminary evaluation of potential annual emissions offsets for the <br /> IRC Class I Landfill based on the summary information provided by SWDD; <br /> • completed and submitted the CCX' s offsets project eligibility questionnaire for <br /> the landfill after review by SWDD ; and <br /> • obtained preliminary approval from CCX. <br /> IRC CCX Propo ].dm <br /> engineers I scientists I innovators <br />