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Ms. Polly Kratman GeoSyntec Consultants <br /> Indian River County <br /> 15 September 2006 <br /> Page 5 <br /> Task 4 — Tier 2 Testine and Renortine <br /> The scope of the Tier 2 testing and reporting task includes the development of a test <br /> plan, field gas sampling, laboratory analysis, data evaluation, and reporting. The NSPS <br /> requires that sampling be conducted using one of two methods : (i) collecting a minimum <br /> of two samples per hectare (2 .47 acres) of existing landfill surface that has retained waste <br /> for at least two years, with a maximum of 50 samples, using stainless steel probes; or (ii) <br /> collecting a minimum of three samples from an existing gas collection system. GeoSyntec <br /> proposes to sample using method (ii) above. It is noted that the following requirements <br /> must be met in order to sample using the above-mentioned method: (i) the entire area of <br /> the landfill that has retained waste for two or more years must be sampled in order to <br /> accurately evaluate the NMOC emission rate from the landfill ; (ii) the samples are <br /> collected prior to gas moving or condensate removal equipment; and (iii) a minimum of <br /> three samples are taken from the gas collection system header. GeoSyntec assumes that all <br /> three of these criteria can be met. <br /> GeoSyntec understands that the Title V permit and NMOC emission rate reporting for <br /> the IRCL facility includes the C &D disposal facility. Therefore, the February 2000 Tier 2 <br /> NMOC sampling program included sampling the C&D disposal facility. Since the C&D <br /> landfill at the IRCL facility has not accepted MSW, it is not subjected to the NSPS <br /> requirements for MSW landfills . GeoSyntec proposes that the C&D disposal facility be <br /> removed from the Title V permit and reporting requirements . GeoSyntec will prepare an <br /> alternate sampling procedure for submittal to FDEP that : (i) requests that three landfill gas <br /> samples be taken from the active gas collection header as described above; and (ii) requests <br /> the C&D landfill be excluded from sampling and NMOC emissions calculations. <br /> GeoSyntec proposes that a meeting be held with FDEP to obtain approval for <br /> modifications to the Title V permit, sampling and reporting requirements . An alternate <br /> sampling procedure for the Class I landfill will be prepared for FDEP approval. <br /> GeoSyntec understands that over 30 landfill gas extraction wells are installed in <br /> Segment 1 , Segment 2, and the Infill area. As a result, GeoSyntec proposes to collect gas <br /> samples from the existing gas collection system at a location prior to the flare station' s <br /> blower and condensate knockout. Three samples will be collected in passivated SUMMA <br /> canisters and sent under chain-of-custody protocol to Triangle Environmental Services in <br /> Research Triangle Park, North Carolina. Samples will be analyzed for nitrogen by EPA <br /> XL06177UL60137.doc <br />