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Mr. Himanshu Mehta, P.E. Managing Director Geospte&
<br />I July 2021
<br />Page 2 consultants
<br />PROJECT BACKGROUND
<br />The IRCL facility is located in southern Indian River County, east of Interstate 95, south of Oslo
<br />Road, and west of Rangeline Road in Vero Beach, Florida. The landfill serves the unincorporated
<br />Indian River County and municipalities of Vero Beach, Orchid, Fellsmere, Sebastian, and Indian
<br />River Shores. The SWDD administers the management and operation of the Class I Landfill at the
<br />IRCL facility, and as such, it is the permit holder of the IRCL facility. This landfill facility is
<br />currently operating under Title V Air Operation Permit No. 0610015 -007 -AV, effective June 1,
<br />2017. The existing Class i Landfill has a voluntarily installed gas collection and control system
<br />(GCCS) for those areas at final, or close to final, grades. Segment 1 vertical expansion, Segment 2,
<br />and the Infill Area of the IRCL have an existing GCCS that consists of vertical and horizontal gas
<br />extraction wells, gas collection lateral and header pipes, blower, and flare. The gas collection
<br />system in Segment 3, Cell 1 of the Class I Landfill is currently under construction and will tie into
<br />the existing GCCS. Collected landfill gas is piped to a flare/blower system, located northeast of
<br />Segment 2, where the combustible components are oxidized by incineration. In 2019 SWDD
<br />constructed Cell 2 of Segment 3 of the Class I Landfill. This cell has been used for waste placement
<br />since 2020 but has no GCCS installed yet.
<br />Geosyntec also understands that the IRCL facility is currently not regulated under the New
<br />Source Performance Standards (NSPS) for municipal solid waste (MSW) landfills as identified
<br />in Subpart WWW of 40 CFR, Part 60 (Subpart WWW). This is either because the Class I
<br />Landfill either commenced construction, reconstruction, or modification on or after May 30,
<br />1991, but before July 18, 2014. Also, even though the IRCL facility had initial design capacity
<br />exceeding 2.5 million Mg and 2.5 million m3 of solid waste, its NMOC emission rate was less
<br />than 50 Mg/yr required by Subpart WWW during the previous permit renewals.
<br />It should be noted that the U.S. Environmental Protection Agency (EPA) published in the
<br />Federal Register, dated August 29, 2016, a subpart (Subpart XXX) that updated the Standards of
<br />Performance of MSW Landfills. Subpart XXX became effective on October 28, 2016 and
<br />applies to MSW landfills for which construction, reconstruction, or modification commenced
<br />after July 17, 2014. Concurrently, the EPA published a new subpart (Subpart Cf) that updates
<br />the Emission Guidelines and Compliance Times for Municipal Solid Waste Landfills, which
<br />applies to MSW landfills that commenced construction, modification, or reconstruction on or
<br />before July 17, 2014.
<br />The EPA subsequently published in the Federal Register, dated May 21, 2021, a new Federal
<br />Plan as 40 CFR 62, Subpart 000. This Federal Plan implements the 2016 emission guidelines
<br />for existing MSW landfills in 40 CFR Part 60, Subpart Cf that are located in states that did not
<br />have approved and effective state plans. This federal plan became effective on June 21, 2021
<br />NCP2021.3236\11,21050 IRC Title V Air Permit Renewal Proposal
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