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Mr. Brendan P. Kenny, RG <br />Corrective Action Program Update - 2Q2025 <br />July 11 2025 <br />Page 2 <br />On 30 April 2025, three gas probes had methane concentrations exceeding 1% by volume. GP- <br />10D had an observed methane content of 42% by volume, GP-10M had an observed methane <br />content of 41.8% by volume, GP-10S had an observed methane content of 35.8% by volume. <br />On 30 April 2025, GP-1AD, GP-1AS, GP-2AD, GP-2AS, GP-6AM, GP-6AS, GP-10D, GP- <br />10M,GP-10S and GP 11S had observed VOC exceedances of 600 ppbv, 3,500 ppbv, 4,500 ppbv, <br />2,000 ppbv, 1,000 ppbv, 2,500 ppbv, 3,000ppbv, 1,500 ppbv, 5,500 ppbv, 6,200 ppbv, 4,600 ppbv <br />and 2,500 ppbv, respectively which were above 10 ppbv. <br />Based on the requirements in the CAO and on the above monitoring results, probes GP-1AD, GP- <br />1AS, GP-2AD, GP-2AS, GP-6AM, GP-6AS, GP-10D, GP-10M,GP-10S and GP 11S will require <br />annual TO-15 sampling due to methane concentrations exceeding 1 percent by volume and VOC <br />concentrations exceeding 10 ppbv. The TO-15 sampling of these probe intervals will be conducted <br />on an annual basis in accordance with the CAO and submitted as part of the Landfill Gas <br />Extraction System Optimization Report. <br />The 2025 second quarter probe monitoring data are shown in Table 1. <br />CONTROL SYSTEM PERFORMANCE MONITORING <br />The site sends its LFG to two onsite flares for combustion and to the onsite landfill gas to energy <br />(LFGTE) plant operated by Ameresco. SCS operated and monitored the GCCS including the flares <br />in the second quarter of 2025. <br />The average flow rates to FL-100 and FL-150 were 1,544 scfm and 1,406 scfm, respectively. The <br />average methane content was 47% by volume at flare FL-100 and 46.8% at flare FL-150. <br />Flare FL-100 had a total run time of 708.73 hours and a total down time of 11.27 hours in April <br />2025, a total run time of 725.93 hours and a total down time of 18.07 hours in May 2025 and a <br />total runtime of 694.78 hours and a total down time of 25.21 hours in June 2025. Flare FL-100 <br />recorded a maximum adjusted flow of 1,680 standard cubic feet per minute (scfm) . <br />Flare FL-150 had a total runtime of 708.72 hours and a total downtime of 11.28 hours in April <br />2025, a total runtime of 713.05 hours and downtime of 30.95 hours in May 2025 and, a total <br />runtime of 663.5 hours and a total downtime of 56.5 hours in June 2025. Flare FL-150 recorded a <br />maximum adjusted flow of 1550 scfm. <br />A plume of methane was detected at the site by a satellite-based instrument on 25 th June 2025. <br />California Air Resources Board (CARB) notifies Republic Services about the same. Flare FL-100 <br />was shutdown from 7:44 am to 7:12 pm, while flare FL-150 was shutdown from 7:44 am to 7:13 <br />pm for source testing. <br />Except for standard flare malfunctions or shutdowns, the GCCS was operated continuously 24 <br />hours per day without any significant downtime flare time. <br />Q2 Corrective Action Program Update - 2025