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Mr. Brendan Kenny <br />January 15, 2025 <br />Page 2 <br />COMPLIANCE TESTING INSTRUMENTATION AND METHODS <br />Testing for methane gas, oxygen gas, carbon dioxide gas and pressure was performed using a <br />Landtec GEM-5000 Gas Analyzer calibrated to methane gas. The instrument measures combustible <br />gas concentrations as a percentage by volume (0 to 100 percent) in the gas sampled. The detection <br />limit for this instrument is approximately 0.10 percent by volume. Compliance testing for gas <br />monitoring probes is included below. <br />Gas Monitoring Probe Testing Procedures <br />•Connect sample tubing, open test valve; observe pressure and record data. <br />•For probes 20 feet deep or less, turn on sample pump, observe and record methane, oxygen, <br />and carbon dioxide gas concentrations, when readings have stabilized for 30 seconds. <br />•For probes more than 20 feet deep, turn on sample pump, extract a minimum of one probe <br />volume, observed and record methane, oxygen, and carbon dioxide gas concentrations, when <br />readings have stabilized for 30 seconds. <br />•Close test valve, disconnect sample instruments and secure sample location. <br />GCCS OPERATIONS AND MAINTENANCE <br />SCS Engineers (SCS) is contracted by Forward to conduct the operation and maintenance (O&M) of <br />the GCCS at the Landfill. During the fourth quarter of 2024, the following O&M activities were <br />conducted: <br />•Quarterly monitoring of LFG probes was conducted; <br />•Ongoing wellfield monitoring and tuning of the GCCS was performed; <br />•Inspection of condensate sumps and pumps for proper operations was conducted. Required <br />maintenance identified as a result of the inspections was performed; <br />•TO-15 testing was performed at the perimeter monitoring probes; <br />•There were no known GCCS system failures during the fourth quarter of 2024. The GCCS <br />operated continuously for 24 hours per day. The flare station experienced standard <br />malfunction, shutdown and startups, including coordinated shutdowns for construction of <br />new vertical LFG wells and associated lateral piping; but there was no significant downtime; <br />and <br />•The instantaneous total flow rate of LFG on December 5, 2024, was 1,390 standard cubic <br />feet per minute (scfm) at the LFG-to-energy (LFGTE) facility, 1,350 scfm at Flare A-2, and <br />1,350 scfm at Flare A-3 1. <br />1 There is a correction in flare identification numbers utilized in previous reports. The nomenclature reported above is correct. In <br />reports prepared between fourth quarter 2021 through third quarter 2024, Flares A-1 and A-2 should have been reported as Flares <br />A-2 and A-3, respectively. Flare A-1 previously existed at the Landfill but was decommissioned in February 2017.