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r <br /> AW <br /> mw RMC LONISTARAiff <br /> 6601 Koll Center Parkway <br /> P.O. Box 5252 <br /> Pleasanton, CA 94566 <br /> (415) 426-8787 <br /> July 28, 1989 �. <br /> Mr. Gordon L. oggs 4'+. <br /> Underground ank Program Coordinator <br /> Californi Regional Water <br /> Control oard <br /> Centr Valley Region <br /> 344 Routier Road, Suite A <br /> Sa ramento, CA 95827-3098 <br /> Re: Site Specific Variance <br /> Dear Mr. Boggs: <br /> RMC Lonestar is requesting a site specific variance for <br /> monitoring two 6,500 gallon underground storage tanks <br /> containing SC grade liquid asphalt at our Tracy Aggregate <br /> Plant - 30350 South Tracy Blvd. , Tracy. <br /> To date, we have been working with the San Joaquin Local <br /> Health District and have requested, in a letter to Jaime <br /> Favila dated June 7, 1989, that a monthly vadose gas testing <br /> program be implemented to monitor these tanks. This request <br /> has been made due to the nature of the material in these tanks <br /> and the physical characteristics of the site. However, this <br /> district requires that the Regional Water Quality Control <br /> Board first approve the variance before the program will be <br /> I allowed in their county. <br /> Our request for a site specific variance is based on the <br /> following facts: 1. Conventional tank testing equipment has <br /> been designed to test liquids that have a relatively low <br /> viscosity, diesel fuel is about 2 to 3 centistokes at 100 <br />` degrees Fahrenheit. At 1.40 degrees Fahrenheit the viscosity <br /> of asphalt is about 250 to 500 centistokes, making the use of <br /> conventional equipment impractical. 2. Testing equipment was <br /> not designed to be used at the high temperatures in which <br /> asphalt must be kept to prevent the material from hardening. <br /> Asphalt is stored at temperatures ranging from 160 to 210 <br /> degrees Fahrenheit. 3 . Inventory reconciliation or tank <br /> gauging could not effectively be achieved. A stick could only <br />