COMPLIANCE INFO_2025 Q3 CORRECTIVE ACTION

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Mr. Brendan P. Kenny, RG Corrective Action Program Update – Q3-2025 October 8 2025 Page 2 Q3 Corrective Action Program Update - 2025 On 16 September 2025, four gas probes had methane concentrations exceeding 1% by volume. GP-1AD had an observed methane content of 1.1% by volume. GP-10D had an observed methane content of 50.1% by volume, GP-10M had an observed methane content of 51.1% by volume, GP- 10S had an observed methane content of 37.2% by volume. On 16 September 2025, GP-1AD, GP-10D, GP-10M, and GP-10S had observed VOC exceedances of 500 ppbv, 6,200 ppbv, 6,800 ppbv and 2,300 ppbv, respectively which were above 10 ppbv. Based on the requirements in the CAO and on the above monitoring results, probes GP-1AD, GP- 10D, 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. 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 2025 third quarter probe monitoring data are shown in Table 1. CONTROL SYSTEM PERFORMANCE MONITORING The site sends its LFG to two onsite flares, FL-100 and FL-150, for combustion and to onsite landfill gas to energy (LFGTE) plant operated by Ameresco. SCS operated and monitored the GCCS including the flares in the third quarter of 2025. The average flow rates to FL-100 and FL-150 were 1,477 scfm and 1,410 scfm, respectively. The average methane content was 50.4% by volume at flare FL-100 and 50.2% at flare FL-150. Flare FL-100 had a total run time of 727.6 hours and a total down time of 16.4 hours in July 2025, a total run time of 726.8 hours and a total down time of 17.2 hours in August 2025 and a total runtime of 720 hours and no down time in September 2025 with total 1.5% downtime during the quarter. Flare FL-100 recorded a maximum flow of 3,221 standard cubic feet per minute (scfm). Flare FL-150 had a total runtime of 727.5 hours and a total downtime of 16.5 hours in July 2025, a total runtime of 699.42 hours and downtime of 44.6 hours in August 2025 and, a total runtime of 720 hours and no downtime in September 2025 with total 2.8% downtime during the quarter. Flare FL-150 recorded a maximum flow of 2,727 scfm. The Ameresco Plant had an average flow rate of 1,209 scfm with a total of 2.6% down time during the 3rd quarter. The average methane content was 52.6%. Overall, during the 3rd quarter, the average LFG flow from the landfill was 4,096 scfm with combustion units operating 97.7% of the time with only 2.3% downtime. Except for standard flare malfunctions or shutdowns, the GCCS was operated continuously 24 hours per day without any significant flare downtime.