COMPLIANCE INFO_2025-2026 - Laserfiche WebLink

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eTools®. All readings are maintained in this secure SCS Database. The readings are not provided in the report due to the volume of readings but can be furnished upon request. Recorded wind speed results are shown in Attachment 6. Wind speed averages were observed to remain below the alternative requested 10 miles per hour, and no instantaneous speeds exceeded 20 miles per hour. No rainfall had occurred within 72 hours of the monitoring events. Therefore, site meteorological conditions were within the requested alternatives of the LMR requirements on the above-mentioned dates. TESTING RESULTS On November 3 and 4, 2025, SCS performed the monitoring on a 25-foot pathway per the rule as required under the LMR. The monitoring intended to identify any specific locations or areas of the landfill surface with organic compound concentrations exceeding the LMR/NSPS threshold limit values of 500 ppmv measured as methane for instantaneous monitoring, or an average methane concentration of 25 ppmv for the integrated monitoring. During the initial instantaneous monitoring,there were thirty-three (33) exceedances of the 500- ppmv limit observed. The required first/second 10-day(LMR/NSPS) and 30-day(NSPS)follow-up monitoring performed on November 14, 24 and December 4, 2025, indicated that not all locations returned below compliance limits as required,following system adjustments and remediation performed by SCS and site personnel. Based on these monitoring results, and in accordance with NSPS, the site is required to perform a system expansion within 120 days of the initial detected exceedance or March 4, 2026. Results of the initial and follow-up monitoring are shown in Attachment 3 (Table 1). Calibration logs for the monitoring equipment are provided in Attachment 5. Additionally, during the integrated monitoring, twelve (12) exceedances of the 25-ppmv limit were observed.The required first and second 10-day LMR follow-up monitoring performed on November 14 and 24, 2025, indicated that not all grid areas had returned to compliance following system adjustments and remediation by site personnel. In accordance with LMR requirements for expansion and remediation, the exceedance locations need to be remediated and returned to compliance in accordance with the rule (expansion of the collection system or an alternative compliance option if approved by the BAAQMD)within 120 days of the third observed integrated exceedance, which will be due by March 24, 2025. However, since the NSPS regulation is from the initial exceedance (from the instantaneous exceedance), we will be using the March 4, 2026, due date for expansion. The initial and follow-up monitoring results are shown in Attachment 4, Table 2. Calibration logs for the monitoring equipment are provided in Attachment 5. PRESSURIZED PIPE AND COMPONENT LEAK MONITORING During monitoring on November 3, 2025, the Landfill Gas (LFG) Blower Flare Station (BFS) was collecting and combusting landfill gas as was the Power Generation Facility(PGF). SCS performed LFG pressurized pipe and component leak monitoring at the BFS. Monitoring was performed with the detector inlet held one-half of an inch from the pressurized pipe and associated components. No locations exceeding the 500 ppmv thresholds were observed during our monitoring event. Note that the PGF was tested by SCS on November 4, 2025, as requested by Ameresco Inc., and those results, which indicated compliance bythe end of monitoring,will be submitted directlyto Ameresco personnel. Foothill Landfill—Fourth Quarter 2025 www.scsenaineers.com 3