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The average benzene concentration of site goils is 1.46 mg/kg. <br /> Equivalent uncontrolled aeration of 12 yards per day of soil with <br /> this benzene concentration would result in an emission of 0.05 <br /> pounds per day (lbs/day) benzene. <br /> We propose that soil venting operations at this site be permitted <br /> to operate with no emission control devices, with the stipulation <br /> that air emissions would be limited to 107 lbs/day TPH and 0.05 <br /> lbs/day benzene. Initial TPH and benzene emission rates for the <br /> soil venting system would be evaluated during a pilot test of the <br /> system. Following establishment of the rates of TPH and benzene <br /> emissions for the system, emissions would be regulated by limiting <br /> the hours of operation of the system and/or system flow rates. Air <br /> dilution would not be utilized to control daily emission rates. <br /> Air emissions would be monitored according to the schedule set <br /> forth in the permit to operate/authority to construct document. <br /> Rule 409.9 calls for no uncontrolled soil aeration after July 1, <br /> 1991, therefore we would like to complete installation of the <br /> above ground components of the soil venting system and commence <br /> the pilot test as soon as approval is obtained from your office. <br /> If you have any questions concerning this proposal or the project <br /> in general, please call. <br /> Sincerely, <br /> NATIONS GROUNDWATER ASSOCIATES <br /> 20 A � <br /> Darrell L. Nations, R.G. <br /> Principal Hydrogeologist <br /> DLN:dn <br /> Enclosure <br /> cc: Mr. Jerry Moore, Moore Petroleum, Inc. <br /> Mr. Greg Lyon, San Joaquin County Public Health Services <br />