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72 Off-Gas Treatment The VES preliminary design estimated TPHg extraction rate is 300 ppd The San Joaquin Valley Unified Air Pollution Control District (SJVUAPCD) requires the treatment of VES process flows that result in the extraction of greater than 1 ppd VES mass extraction rates of less that 1 ppd can be vented directly to the atmosphere, whereas potential emissions greater that I ppd require treatment to ' reduce the emission by a minimum of 95% prior to atmospheric discharge Vapor treatment of TPHg is typically accomplished through the use of incineration or carbon-based treatment units Based on an anticipated start-up VES process concentration of approximately 33,000 mg/m3, the use of a ' therm-ox will initially provide the most cost effective control technology The cost effectiveness discussed herein is based on the cost to extract and process TPHg on a per pound basis at the ' concentrations expected Other viable control technologies such as an internal combustion engine or carbon adsorption will have operation and treatment costs greater than thermal oxidation The ' control technology for the VES off-gas will consist of a natural gas supported therm-ox rated at 150 scfm A vapor extraction system process flow schematic is depicted on Figure 8 73 VES Design The CAP section included herein forms the basis for the detailed engineering design of the VES Regulatory review and approval of this PAR/CAP by San Joaquin County Public Health Services (SJCPHS) is necessary prior to initiating engineering design Regulatory approval of this PAR/CAP provides concurrence from SJCPHS with the remediation technology and methods proposed to provide site remediation Upon approval of this report by SJCPHS, the preparation of operating permit submittals and engineering plans can proceed A construction and operation permit (Authority ' to Construct and Permit to Operate) is required from the SJVUAPCD Engineering plans form the basis for plan review and building permit issuance by the City of Stockton Public Works and ' Planning Departments The building permit plan review and field inspections required for the construction of the VES principally relate to the new electrical and natural gas services required to operate the proposed therm-ox The plans also are necessary to depict the construction methods necessary to install the new electric and natural gas services in accordance with Pacific Gas and Electric (PG&E) requirements In addition, detailed engineering plans form the basis from which ' competitive construction bids can be obtained from qualified general contractors licensed to perform remediation construction ' A recommended minimal content for engineering plans for the VES is as follows ' C Site map showing the entry and termination routes for new electric and natural gas services, VES trench routes and remediation compound/fencing locations The proposed remediation compound location shown on Figure 7 is not considered permanent and could be proposed ' elsewhere onsite 1 Project No 38100-06-18A -17- December 9, 1996