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Mr..Himanshu Mehta, P.E. Managing Director Geosptecl�' I July 2021 Page 3 consultants and applies to MSW landfills that commenced construction, modification, or reconstruction on or before July 17, 2014 and have not been modified (i.e., increase in permitted volume design capacity through vertical or horizontal expansion) since July 17, 2014. One of the significant changes to the HSPS requirements under 40 CFR 60, Subparts XXX and Cf and 40 CFR 62, 000 is to reduce the NMOC emission threshold from 50 megagrams per year (Mg/yr) to 34 Mg/yr. Facilities that exceed the new threshold are required to purchase, install, and operate a GCCS. The new rule also requires the submission of the following reports to the EPA no later than September 20, 2021: (i) Design Capacity report; and (ii) NMOC emission rate report. Based on our preliminary understanding and interpretation of the latest Federal Plan, the IRCL facility will be subject to Subpart 000 including a lowered NMOC emission threshold and requirement to submit to EPA the above two reports. A 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 2016. A Title V Air Operation Permit Revision application was submitted in November 2018 to incorporate two emergency standby generator units that were installed later on. A similar Tier 2 testing previously conducted for the December 2016 application 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 2021 permit renewal application in addition to the submittal required by EPA. PROPOSED SCOPE OF WORK This project includes professional engineering services required to renew the Title V Air Operation Permit for the IRCL facility. The scope of work is based on the requirements of Chapter 403 of the Florida Statue (F.S.), Chapters 62-4, 62-210 and 62-213 of the Florida Administrative Code (F.A.C.), and Geosyntec's understanding of the project based on information provided by SWDD and the NSPS requirements. Geosyntec will provide all engineering services necessary to prepare the 5 -year permit renewal application, including Tier 2 testing to calculate the NMOL, and address any RAI from FDEP. For budgeting purposes, the scope of work will be performed in four phases as follows: • Phase 1— General Consulting/Meeting Support/Project Management; • Phase 2 — Design Capacity and NMOC Emission Rate Reports; • Phase 3 — Title V Permit Renewal Application; and • Phase 4 — Response to Regulatory Comments. NCP2021-3236\JL21050�1RC Title V Air Permit Renewal Proposal engineers I scientists I innovators