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Ms . Polly Kratman GeoSyntec Consultants <br /> Indian River County <br /> 15 September 2006 <br /> Page 6 <br /> Method 3C to validate the sample (i. e., confirm minimal air intrusion occurred) . Upon <br /> sample validation, the samples will be analyzed for NMOCs by EPA Method 25C . <br /> Upon completion of gas sampling and analysis, GeoSyntec will review the analytical <br /> results, estimate annual NMOC mass emission rates, and prepare an NSPS Tier 2 NMOC <br /> emissions rate report that summarizes sampling and analysis activities and results. Data <br /> analysis will include the calculation of NMOC concentrations based on laboratory analysis <br /> and waste acceptance rates . GeoSyntec will use the EPA ' s Landfill Gas Emissions Model <br /> Version 3 . 02 to estimate the NMOC emission rate. Results and conclusions regarding the <br /> need for compliance with the additional NSPS monitoring and reporting requirements of <br /> the Class I landfill will be based on the regulatory threshold of 50 Mg/yr of NMOC <br /> generation. <br /> Task 5 — Miscellaneous Compliance and Technical Support <br /> Under this task, GeoSyntec will provide SWDD with technical support and other <br /> miscellaneous compliance services related to the operations of the Class I landfill and <br /> C&D disposal facility. The miscellaneous compliance and reporting services will include: <br /> (i) preparation of annual operating permit reports; (ii) compliance monitoring requirements <br /> of the Multi- Sector Generic Permit for stormwater discharge; (iii) providing oversight of <br /> the annual testing of the flare emissions and reporting the results to FDEP ; (iv) quarterly <br /> monitoring/reporting of the 10 landfill gas monitoring wells located at the IRCL site <br /> boundary, as well as enclosed structures located on site; (v) submittal of records of <br /> groundwater dewatering volumes to St. Johns River Water Management District ( SJWMD) <br /> in compliance with the consumptive use water permit; (vi) engineering support for <br /> preparation of agenda items to District Board and the development of annual budgets ; and <br /> (vii) other required renewal permits or technical support that may become necessary. <br /> GeoSyntec will also assist SWDD in evaluating the eligibility of the IRCL facility under <br /> the Chicago Climate Exchange (CCX) Landfill Methane credits program. <br /> XL06177'JL60137.doc <br />