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IAW AMW RMC LOaESTAR .� 6601 Koll Center Parkway PO. Box 5252 Pleasanton, CA 94566 (415) 426-8787 July 28 , 1989 Mr. Gordon L. Boggs Underground ank Program Coordinator Californi Regional Water Control oard Cent r Valley Region :�' 344 Routier Road, Suite A w,�0'.�C S Rv\G� Sa ramento, CA 95827-3U98 0 Re: Site Specific Variance Dear Mr. Boggs: RMC Lonestar is requesting a site specific variance for monitoring two 6 , 500 gallon underground storage tanks containing SC grade liquid asphalt at our Tracy Aggregate Plant - 30350 South Tracy Blvd. , Tracy. To date, we have been working with the San Joaquin Local Health District and have requested, in a letter to Jaime Favila dated June 7 , 1989, that a monthly vadose gas testing program be implemented to monitor these tanks. This request has been made due. to the nature of the material in these tanks 3 and the physical characteristics of the site. However, this district requires that the Regional Water Quality Control Board first approve the variance before the program will be allowed in their county. Our request for a site specific variance is based on the following facts: i. Conventional tank testing equipment has been designed to test liquids that have a relatively low viscosity, diesel fuel is about 2 to 3 centistokes at 100 degrees Fahrenheit. At 140 degrees Fahrenheit the viscosity of asphalt is about 250 to 500 centistokes, making the use of conventional equipment impractical. 2 . Testing equipment was not designed to be used at the high temperatures in which asphalt must be kept to prevent the material from hardening. Asphalt is stored at temperatures ranging from 160 to 210 degrees Fahrenheit. 3 . Inventory reconciliation or tank gauging could not effectively be achieved. A stick could only