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Corrective Action Plan page 26 <br /> Exhausted carbon from the treatment units is removed from the vessels at the time they <br /> are recharged and held on site in United States Department of Transportation (DOT) <br /> approved containers until the material has been profiled When profiling is complete, the <br /> spent-carbon containers are transported to the carbon vendor's facility under control of the <br /> requisite DOT waste transport manifest On arrival at the vendor's facility the adsorbed <br />' contaminants are extracted from the carbon in a permitted re-activation plant and a <br /> certificate of VOC destruction issued so that the material can be recycled in beneficial use <br />' A Waste Generator's Number issued by the California EPA will be obtained to comply <br /> with the applicable regulations that control the off-site disposal of the spent carbon <br /> Process f1m and Control <br />' instrumentation for the proposed groundwater recovery and treatment system is shown <br /> schematically on as Figure 10 and listed on Figure 11 A comprehensive system of control <br /> valves is provided to permit all treatment units to be shut out of the system and bypassed <br />' and for the system to be assembled (and, as necessary, disassembled and reassembled) <br /> within the restricted space available on the site The system is fabricated from simple <br /> components and materials to permit its layout and operation to be adapted to working <br /> t conditions as they are found in the field There are no automated controls or switching <br /> systems and it is intended that it will operate under manual control Operators will be <br /> present at all times that the system is in use <br /> AIL-Quality Concerns <br />' Under SJVUAPCD Rule 2020 an Authority to Construct and a Permit to Operate is not <br /> required for any process unit if the uncontrolled emissions of air contaminants does not <br /> exceed 2 pounds in any 24 hour period (Ref 6) <br /> 1' <br /> If it is conservatively assumed that all of the components of fuel hydrocarbons in the <br />' affected groundwater are volatile and that they will be totally removed in the sparge tank <br /> units of the treatment system, the concentration of total petroleum hydrocarbons in the <br /> stream of water passing through the treatment system, if it were to operate continuously, <br /> 24 hours per day at its rated hydraulic capacity of 45 gpm, would have to be 8 33 mg/Liter <br /> (ppm) before emissions from the sparging tanks would be equal to the regulatory limit of <br /> 2 lb per day For the reasons discussed below, it is extremely unlikely that this limit will <br /> I be approached However, as is also described later, provision has been made to manage <br /> any unexpected increase in contaminant loading that might occur <br /> As has been previously discussed, a conservative estimate of 3 62 mg/Liter for the <br /> maximum total concentration of dissolved petroleum hydrocarbons in the influent stream <br /> to the groundwater treatment has been made for the purpose of sizing the process <br /> equipment That estimate is conservative because it was derived from the results of <br /> analyses of groundwater samples recovered from monitoring wells in the most <br /> contaminated zones beneath the site and considered historical data that includes single- <br />