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Mr. Jim Swaney <br /> San Joaquin Valley Air Pollution Control District <br /> Page 2 <br /> day, or approximately 20.6 gallons of LPG for every gallon of hydrocarbons removed from the <br /> subsurface. <br /> Ground Zero hereby requests modification of Permit to Operate No. N-6574 to allow operation of <br /> the unit as a liquid-ring blower only, with no off-gas treatment. Based upon historical operating <br /> parameters (Table 2) and analytical results (Table 3), the estimated VOC emissions from the soil <br /> remediation system without any vapor abatement would be between 0.10 and 0.40 pounds per day. <br /> Based upon this information, direct discharge of VOCs extracted from the surface would be below <br /> the limits established in the permit requirements (Requirement #7) of 2 pounds per day maximum. <br /> Ground Zero would continue sampling to demonstrate ongoing compliance with the VOC emission <br /> rate. <br /> Please feel free to call me at (209) 838-9888 if you have any questions regarding this submittal. <br /> Respectfully, <br /> Ground Zero Analysis, Inc. <br /> John P. Lane <br /> CA Registered Geologist No. 6795 <br /> Enclosure <br /> Cc: Mr. Jim Barton; RWQCB-Central Valley Region <br /> Mr. Jeff Wong, San Joaquin County EHD <br /> GAGROUNMEMLEBURGNVapor Extraction permits\APCD directdiseharge.doc <br />