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2011-235
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Mr. Himanshu Mehta, P . E . Managing Director <br /> 3 November 2011 <br /> Page 3 <br /> Phase 1 — General Consulting/Meeting Support/Project Management <br /> Under this phase , Geosyntec will perform project planning and management responsibilities, <br /> such as correspondence with SWDD and FDEP, invoice review , project coordination, budget and <br /> schedule tracking and project administration . Geosyntec has also included a budget for <br /> preparation and attendance (by two Geosyntec personnel ) at two meetings : (i ) kickoff meeting <br /> with SWDD staff to obtain information required to complete the application ; and (ii ) a meeting <br /> with FDEP and SWDD to present the complete application and respond to questions . <br /> Phase 2 —Tier 2 Testing and Reporting <br /> The scope of the Tier 2 testing and reporting phase includes the development of a test plan , field <br /> gas sampling, laboratory analysis, data evaluation , and reporting . We will collect gas samples <br /> from the existing gas collection system at a location prior to the flare station ' s <br /> blower and <br /> condensate knockout . Three samples will be collected in passivated SUMMA canisters and sent <br /> under chain - of- custody protocol to an analytical laboratory for testing . Samples will be analyzed <br /> for nitrogen by EPA Method 3C to validate the sample ( i . e . , confirm minimal air intrusion <br /> occurred ) . Upon sample validation , the samples will be analyzed for NMOCs by EPA Method <br /> 25C . Sample collection and analysis will be performed by TRC Environmental Corporation , <br /> Gainesville , Florida (TRC ) as a subcontractor to Geosyntec . A copy of TRC ' s proposal is <br /> included as Attachment A . <br /> Geosyntec will review the analytical results , estimate annual NMOC mass emission rates, and <br /> prepare an NSPS Tier 2 NMOC emissions rate report that summarizes sampling and analysis <br /> activities and results . Data analysis will include the calculation of NMOC concentrations based <br /> on laboratory analysis and waste acceptance rates . Geosyntec will use the EPA ' s Landfill Gas <br /> Emissions Model Version 3 . 02 to estimate the NMOC emission rate . Results and conclusions <br /> regarding the need for compliance with the additional NSPS monitoring and reporting <br /> requirements of the Class I landfill will be based on the regulatory threshold of 50 Mg/yr of <br /> NMOC generation . <br /> Phase 3 — Title V Renewal Permit Application <br /> Geosyntec will prepare the FDEP Title V Air Operation renewal permit application for the IRC <br /> landfill . Geosyntec will complete FDEP, Division of Air Resource Management Form No . 62 - <br /> 210 . 900 ( 1 ) titled "Application for Air Permit - Long Form " and address the additional <br /> information items required by the form . The following activities will be performed to prepare <br /> the renewal permit application : <br /> NCP201 I \XL11275\JLl 1126 Title V Proposal . doc <br /> engineers P Scientists I innovators <br />
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