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Rutan & Tucker, LLP <br />13 July 2023 <br />Page 4 <br />At 30707 Corral Hollow Road where the historical City of Tracy Landfill was situated, methane <br />was detected in only one location above the 27 CCR explosive gas control compliance level, with <br />the concentration localized to an area at this property's southwestern boundary adjacent to <br />Interstate 580. Methane concentrations decreased moving away from this probe to levels that <br />were two to four orders of magnitude below this compliance level in the other three probes <br />which are located approximately 450 to 800 feet away, thereby demonstrating the lack of <br />methane migration from this localized area. Given the age of the buried waste, disposed at least <br />76 years ago, continued generation of methane at higher concentrations would not be <br />expected. Rather, methane concentrations being generated by the buried waste will continue to <br />attenuate overtime, thereby, further reducing the potential for migration. <br />At 30600 Corral Hollow Road, methane concentrations were not detected in either vapor probe. <br />The lack of methane concentrations detected in these two probes provide further evidence that <br />methane migration is not occurring from the buried waste present at the adjacent historical City <br />of Tracy Landfill. <br />At the Tracy Hills Phases 2, 3, and 4 property, which is located northwest of both the closed <br />Corral Hollow Landfill and historical City of Tracy Landfill, methane concentrations were not <br />detected in any of the 12 vapor probes. <br />The closed Corral Hollow Landfill contains an active landfill gas collection system operated by <br />the County as required by law, with the methane generated within this landfill being captured <br />and controlled by this system. Quarterly monitoring performed demonstrates the continued <br />effectiveness of this system in preventing methane migration as no methane concentrations are <br />being detected outside the landfill in the nine perimeter gas monitoring wells. Three of these <br />monitoring wells are located between this landfill and the adjacent Tracy Hills Phases 2, 3, and 4 <br />property, and have consistently detected no methane concentrations since quarterly monitoring <br />began in 2006. The landfill gas collection system is required to remain operational and routinely <br />monitored until methane is no longer being generated at concentrations above the 27 CCR <br />compliance level. <br />Given the findings presented in this memorandum, methane mitigation and monitoring measures are <br />not recommended for either the Tracy Hills Phases 2, 3, and 4 property or 30600 Corral Hollow Road/KT <br />Property/Hillview. <br />\\haleyaldrich.com\sharelCF\Projec[s\0208051\Deliverables\2023.06XX_Memo\2023-0713-HAI-Rutan Memo F.dou <br />DL.DRICH <br />