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Mr. Himanshu Mehta, P.E. Managing Director 21 September 2016 Page 4 samples will be collected from predetermined locations, marked and flagged by Geosyntec. Geosyntec has assumed that SWDD would provide a front-end loader and operator to assist with the placement of the gas probes into the landfill. The samples will collected 24 hours following probe placement into 6 or 8 liter SUMMA passivated canisters. Three sample locations will be composited into one canister, resulting into a total of three additional samples collected from Cell 1. The six samples will be sent under chain-of-custody protocol to an analytical laboratory for testing. Samples will be analyzed for: (i)NMOC by EPA Method 25C; (ii) Oxygen (02) by EPA Method 3C; (iii)Nitrogen (N2) by EPA Method 3C; (iv) Methane (CH4) by EPA Method 3C; and Carbon Dioxide (CO2) by EPA Method 3C. Sample collection and analysis will be performed by TRC Environmental Corporation (TRC), Gainesville, Florida as a subcontractor to Geosyntec. A copy of TRC's proposal is included as Attachment A. Geosyntec will review the analytical results, estimate annual NMOL mass emission rates, and prepare an NSPS Tier 2 NMOC emissions rate report that summarizes sampling and analysis activities and results. Data analysis will include the calculation of NMOC concentrations based on laboratory analysis and waste acceptance rates. Geosyntec will use the EPA's Landfill Gas Emissions Model Version 3.02 to estimate the NMOC emission rate. Results and conclusions regarding the need for compliance with the NSPS monitoring and reporting requirements of the Class I Landfill will be based on the regulatory threshold of 34 Mg/yr of NMOC emissions. Phase 3—Title V Permit Renewal Application Geosyntec will prepare the FDEP Title V Air Operation Permit renewal application for the IRCL facility. Geosyntec will complete FDEP, Division of Air Resource Management Form No. 62- 210.900(1) titled "Application for Air Permit - Long Form" and address the additional information items required by the form. The following activities will be performed to prepare the permit renewal application: • Facility plot plan; • Process flow diagram; • Precautions to prevent emissions of unconfined particulate matter; • List of insignificant activities; • Identification of applicable requirements; • Compliance report and plan NCP2016-2255UL16043_Title V Air Permit Renewal Proposal.doe engineers I scientists I innovators