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COMMENTS TO ATTACHMENT A LANDFILL GAS COLLECTION FIELD AND FLARE STATION DATA This Attachment appears to include much of the monitoring presently done at the Corral Hollow landfill gas field and perimeter monitoring probes taken from the County data sheets. In light of the objectives of the CDO, we respectfully submit the following suggestions, as reflected in the proposed revised Attachment A. These suggestions include: • Arrange the data according to the items being monitored (Well Field, Flare Station, and Perimeter migration monitoring wells). • Avoid duplication of data, such as methane and VOC concentration into the flare station. Use units now in use, such as"in. H2O" instead of"in. HG". • Measure VOC concentration at the flare station quarterly, coinciding with the period of the perimeter migration monitoring probes VOC samples. Note: changes in VOCs in the collected.gas will reflect dilution of the gas by intrusion of air, and would not be expected to reflect "clean up" of the groundwater. We would suggest that this measurement is not useful, and could be removed. • Measure perimeter migration monitoring probes quarterly (rather than monthly) in accordance with the requirements of Title 27 and present practice. Monthly monitoring will not yield useful information. Presently, and for the past years, methane content has been zero at all probes except, occasionally, GW-6, which is not in our area of interest. • Measure temperature at the LFG well head once per month. The original Attachment A required temperature measurement before'and after adjustment of flow rate, based on the incorrect assumption that adjusting the flow rate of the LFG well will affect the temperature of the gas collected. However, the temperature of the collected gas does not change perceptibly with adjustment of flow rate. • Some parameters, such as total LFG volume, ambient temperature and barometric pressure, are collected in compliance with other regulations and are not relevant to the purposes of the CDO. These parameters need not be included. Note that the County will continue to provide the results of the LFG well field and flare station monitoring, which include the parameters required by these other regulations, in the periodic groundwater quality reports. However, collecting this other data need not be enforced by this CDO. Comments to Second Draft CDO 6 San Joaquin County Submitted February 28,2013 Public Works/Solid Waste