COMPLIANCE INFO_2025 QTRLY CORRECTION ACTION PLN UPDATES

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Mr. Brendan P. Kenny, RG Corrective Action Program Update - 1Q2025 April 10 2025 Page 2 Corrective Action Program Update - 2025_Draft observed methane content of 4.9% by volume, GP-10S had an observed methane content of 2.2% by volume, GP-11D had an observed methane content of 2.8% by volume, and GP-11S had an observed methane content of 32.7% by volume. On 19 March 2025, GP-10D, GP-10M and GP-10S had observed VOC exceedances of 4,000 ppbv, 5,000 ppbv, and 3,600 ppbv, respectively which were above 10 ppbv. Based on the requirements in the CAO and on the above monitoring results, probes GP-10S, GP- 10M, and GP-10S will require annual TO-15 sampling due to methane concentrations exceeding 1 percent by volume and VOC concentrations exceeding 10 ppbv. Moreover, probe intervals GP- 11S and GP-11D will require annual TO-15 sampling due to high methane detection exceeding 1% by volume. The TO-15 sampling of these probe intervals will be conducted on an annual basis in accordance with the CAO and submitted as part of the Landfill Gas Extraction System Optimization Report. The first quarter of 2025 probe monitoring data are shown in Table 1. CONTROL SYSTEM PERFORMANCE MONITORING The site sends its LFG to two onsite flares for combustion and to the onsite landfill gas to energy (LFGTE) plant operated by Ameresco. SCS operated and monitored the GCCS including the flares in the first quarter of 2025. The average flow rates to FL-100 and FL-150 were 1,262 scfm and 1,424 scfm, respectively. The average methane content was 46% volume at both flares, FL-100 and FL-150. Flare FL-100 had a total run time of 716.67 hours and a total down time of 27.33 hours in January 2025, a total run time of 672 hours and no downtime in February 2025 and, a total run time of 743.9 hours and a total down time of 0.1 hours in March 2025. Flare FL-100 recorded a maximum adjusted flow of 1,600 standard cubic feet per minute (scfm). Flare FL-150 had a total runtime of 716.25 hours and a total downtime of 27.75 hours in January 2025, a total runtime of 671 hours and downtime of 1 hour in February 2025 and, a total run of 743.9 hours and a total down time of 0.1 hours in March 2025. Flare FL-150 recorded a maximum adjusted flow of 1,700 scfm. Except for standard flare malfunctions or shutdowns, the GCCS was operated continuously 24 hours per day without any significant downtime flare time. EXTRACTION WELLS SCS has performed operation and maintenance of the GCCS including extraction wells monitoring and tunning, pipe maintenance, condensate management system inspection and maintenance.