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Mr. Himanshu Mehta, P.E. Managing Director 21 September 2016 Page 2 PROJECT BACKGROUND The IRCL facility is located in southern Indian River County, east of Interstate 95, south of Oslo Road, and west of Rangeline Road in Vero Beach, Florida. The landfill serves the unincorporated Indian River County and municipalities of Vero Beach, Orchid, Fellsmere, Sebastian, and Indian River Shores. The SWDD administers the management and operation of the Class I Landfill at the IRCL facility, and as such, it is the permit holder of the IRCL facility. This landfill facility is currently operating under Title V Air Operation Permit No. 0610015-003-AV, effective July 15, 2012. The existing Class I Landfill has a voluntarily-installed gas collection and control system (GCCS) for those areas at final grades. Segment 1, Segment 2, and the Infill Area of the IRCL have an existing GCCS that consists of vertical and horizontal gas extraction wells, gas collection lateral and header pipes, blower, and flare. Collected landfill gas is piped to a flare/blower system, located northeast of Segment 2, where the combustible components are oxidized by incineration. In 2012, SWDD entered into an agreement for the sale of the landfill gas to INEOS New Planet Bioenergy, LLC (INPB) for use as a supplemental fuel for waste-to-ethanol facility adjacent to the IRCL facility. In 2013 SWDD constructed Cell I of Segment 3 Expansion of the Class I Landfill. This cell has been used for waste placement since 2013 but has no GCCS installed yet. Geosyntec also understands that the IRCL facility is currently not regulated under the New Source Performance Standards (HSPS) for municipal solid waste (MSW) landfills as identified in Subpart WWW of 40 CFR, Part 60 (Subpart WWW). An NSPS Tier 2 NMOC emissions rate report was prepared and submitted to FDEP as part of the Title V Air Operation Permit Renewal application in December 2011. A similar Tier 2 testing will be performed to estimate the site- specific NMOC concentration to recalculate and submit a Tier 2 NMOC emission rate report as part of this 2016 permit renewal application. It should also be noted that the U.S. Environmental Protection Agency (EPA) published in the Federal Register, dated August 29, 2016, a new subpart (Subpart XXX) that update the Standards of Performance of MSW Landfills. The new Subpart XXX becomes effective on October 28, 2016 and applies to MSW landfills for which construction, reconstruction, or modification commenced after July 17, 2014. Concurrently, the U.S. EPA published a new subpart (Subpart Co that updates the Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills, which applies to MSW landfills that commenced construction, modification, or reconstruction on or before July 17, 2014. One of the significant changes to the NSPS requirements under Subparts XXX and Cf is to reduce the NMOC emission threshold from 50 megagrams per year (Mg/yr) to 34 Mg/yr. Since all the active and/or closed cells of the Class I Landfill at IRCL facility were constructed before July 17, 2014 the facility will be subject to Subpart Cf. However, Tier 2 testing will have to be performed in Cell I of Segment 3 Expansion since it has contained waste for at least two years. NCP2016-2255UL16043_Title V Air Permit Renewal Proposal.doc engineers I scientists I innovators