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)owl <br /> Nations Groundwater Associates 0 <br /> HYDROGEOLOGISTS&GEOLOGISTS s <br /> November 20, 1990 <br /> Mr. Lakhmir Grewal L <br /> San Joaquin County Air NOV 2 6 199411 <br /> Pollution Control District <br /> P.O. Box 2009 ENVIRONNIENTAL. HEALTH <br /> Stockton, CA 95201 PERMiIT/SERVICES <br /> Subject: AP 89-439 <br /> Soil Vapor Extraction System <br /> Moore Petroleum, Inc. <br /> 1399 E. Yosemite Avenue. <br /> Manteca, California <br /> NGA Project No. 10-90-479 <br /> Dear Mr. Grewal: <br /> On behalf of Moore Petroleum, Inc. this letter will present a <br /> proposal for operation of a soil vapor extraction system at the <br /> subject site. As we discussed earlier today, Moore Petroleum, Inc. <br /> seeks to operate a soil venting system at this site without the use <br /> of air emission control devices. Previous communication (letter <br /> dated April 28, 1990, Triad Groundwater Associates to Mr. Ali <br /> Othman, SJAPCD) has indicated that the use of air emission control <br /> devices is not cost effective for this site. In lieu of using air <br /> emission control devices to control air emissions, we propose to <br /> limit air emissions to a rate that would be equivalent to the <br /> emissions rate for above ground, uncontrolled aeration of soil as <br /> presented in rule 409.9 of the Air Pollution Rules and Regulations <br /> of the San Joaquin County Air Pollution Control District. <br /> Laboratory analytical results of soil samples taken below the <br /> underground storage tanks (USTs) at the site indicate an average <br /> total petroleum hydrocarbon (TPH) concentration of 2149 milligrams <br /> per kilogram (mg/kg) for soils that have been proposed for soil <br /> vapor extraction. Based on rule 409.9, a concentration of 2149 , <br /> mg/kg (ppm) would fall in the category of 2000-2999 ppm. Rule <br /> 409.9 states that for soil falling within this concentration <br /> range, a maximum of 12 yards could be aerated per day. Based on <br /> the upper concentration limit of this category of 2?99 ppm and a <br /> soil weight of 110 pounds per cubic foot (lbs/ft ) , total airy <br /> emissions that would result from uncontrolled aeration of 12 yards <br /> of soil would be about 107 pounds per day (lbs/day) of TPH. <br /> 3050 Fite Circle,Suite 101 Sacramento,California 95827 (916)361-8095 <br /> (916)362-1380 FAX <br />