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North County Landfill <br /> Landfill Methane Rule (LMR) Surface Emissions Monitoring <br /> Fourth Quarter 2025 <br /> INTRODUCTION <br /> This letter provides the results of the November 11, 21 and December 1, and 11, 2025, LMR and <br /> NSPS surface emissions monitoring(SEM) performed by SCS Field Services (SCS) at the subject site. <br /> All work was performed in accordance with our approved contract dated, November 2018, and LMR <br /> requirements. <br /> SUMMARY AND CONCLUSIONS <br /> On November 11, 2025, instantaneous surface emissions testing showed ten (10) exceedances of <br /> the LMR instantaneous threshold limit of 500 parts per million by volume (ppmv)for instantaneous <br /> monitoring. Based on these monitoring results, corrective actions were taken, and follow-up <br /> monitoring was conducted as required. These results are discussed in a subsequent section of this <br /> report. <br /> In addition, during the instantaneous monitoring event, SCS performed simultaneous integrated <br /> monitoring of the landfill surface. During the monitoring events, eight(8) grid areas were observed to <br /> exceed the 25-ppmv limit for integrated monitoring. Based on these monitoring results, corrective <br /> actions were taken, and follow-up monitoring was conducted as required. These results are <br /> discussed in a subsequent section of this report. <br /> SCS performed integrated monitoring of the landfill surface as required by the LMR, the landfill was <br /> divided into 50,000 square foot areas. The North County Landfill surface area was therefore divided <br /> into 84 grids, as shown in Figure 1-A in Attachment 1. <br /> In addition, quarterly monitoring of the pressurized piping or components of the Gas Collection and <br /> Control System (GCCS)that are under positive pressure must be performed quarterly. Results of the <br /> testing of the landfill gas (LFG) Blower Flare Station (BFS) pressurized pipe and components <br /> indicated that all test locations were in compliance with the 500 ppmv requirements. <br /> Further, as required under the LMR, any location on the landfill that has an observed instantaneous <br /> methane concentration above 200 ppmv must be stake-marked and Global Positioning System <br /> (GPS) located on a site figure. One (1) location was observed during this monitoring event. When <br /> locations are observed to exceed the 200 ppmv threshold, they are shown in the figure in <br /> Attachment 3. <br /> As stipulated in the LMR, upon completion of four consecutive SEM events without an exceedance of <br /> the 25 ppmv or 500 ppmv standards, other than non-repeatable momentary readings, the landfill <br /> may request an exemption from the more stringent monitoring required by the rule and apply for a <br /> 100-foot spacing requirement on an annual basis for closed landfills or quarterly for active disposal <br /> North County Landfill—Fourth Quarter 2025 www.scsenaineers.com <br /> 1 <br />