Permitting Procedures Manual. Soil/Groundwater Remediation

Permitting Procedures Manual Soil/Groundwater Remediation Revised: December 18, 2013

A. DESCRIPTION A typical soil and/or groundwater remediation system consists of both a vapor extraction system used to extract vapors from the contaminated area and a control device used to control emissions from the vapor extraction system. The types of systems included in this manual are in-situ soil vapor extraction systems (SVE), ex-situ soil burners, air stripping systems, ex-situ soil aeration, bioremediation projects, contaminated soil excavations, contaminated soil stockpiles, and air pollution control devices for soil and groundwater remediation. Separate permit application forms with the appropriate fees are required for the vapor extraction system and each control device used at the site. The permit application consists of form G100, form HRA100, and the appropriate supplemental forms located on the SMAQMD website (www.airquality.org). B. PERMIT APPLICATIONS 1. Permit Application Requirements A Permit to Operate is required for each of the following pieces of equipment or ex-situ soil remediation projects: a. Portable or stationary in-situ soil vapor extraction systems, ex-situ soil burners (rotary kiln), soil aeration, or soil excavations unless exempt. b. Portable or stationary air stripping units for groundwater treatment systems including well manifold and blower motor unless exempt. (See Section B2). c. Portable or stationary air pollution control system: carbon adsorption. d. Portable or stationary air pollution control system: oxidizers/hcl scrubbers/baghouses. e. Portable or stationary air pollution control system: IC engines/three-way catalytic converters. f. Portable or stationary air strippers. g. All other mobile or stationary air pollution control systems. h. Portable internal combustion (IC) engines greater than 50 horsepower as determined by test procedure SAE J1349 or SAE J1995 or IC engines that are less than 50 horsepower and are used as an emission control device for a duration longer than 5 days. i. All ex-situ soil aeration projects unless exempt. j. Ozone injection systems or air sparge systems (unless exempt). k. Returning to a site to perform a second pilot test resulting in a cumulative onsite time of more than 5 days unless exempt. Note: Approval of the site remedial action work plan must first be obtained from the Sacramento County Environmental Management Department, Division of Hazardous Materials or the California Water Quality Control Board. XIX-2

2. Permit to Operate Exemptions a. A Permit to Operate is not required for an individual source if it is determined by the Air Pollution Control Officer that the soil or groundwater remediation system has total uncontrolled VOC emissions that are less than 2 lbs/day and the risk assessment for toxic air contaminants results in an excess cancer risk of less than 0.1 in one million. In addition, the acute and chronic hazard index may not exceed 1. b. Pilot tests may be exempt from permitting providing the following: the test is 5 days or less in duration, an emission control device is used during the testing period, the equipment used for testing is exempt from permitting requirements as defined in Rule 201, a soil vapor extraction system has not been operated previously at the site (unless written approval is granted by the SMAQMD on a case-by-case basis), and written approval has been given by the Air Pollution Control Officer (APCO). A written proposal for an exemption is required at least 7 working days prior to the expected test start date. The request shall include: i. The date and time of test ii. Location of test iii. Purpose of test iv. Duration of test v. A system layout vi. The manufacturer s specifications for the proposed emission control device vii. Any support equipment used during the test viii. Contaminants of concern at the site ix. Lab data for samples taken from the site x. Expected emission rates, and carbon usage rate (if applicable) In addition, the SMAQMD must be notified in writing if the test start or end dates change. An exemption for a pilot test lasting longer than 5 days and/or a second pilot test at a location with a cumulative onsite time of more than 5 days may be approved on a case-by-case basis depending on the specific circumstances requiring a longer testing period or a second test. In addition, any control device or control equipment in which the published manufacturer s specification exceeds the exemption limit set by the SMAQMD will not be exempt and will require a permit. For example, an IC engine that is rated over 50 horsepower or a gas fired oxidizer that is rated at or above 1,000,000 BTU/HR. c. Any soil aeration project involving exclusively hydrocarbons with a boiling point of 302 F or greater shall be exempt from permitting and BACT requirements. In addition, any aeration project involving gasoline contaminated soil with an average TPHg concentration of 50 ppm by weight or less or involving 5 cubic yards of soil or less per facility shall be exempt from permitting and Best Available Control Technology (BACT) requirements. However, if elevated benzene concentrations exist in the soil, a screening health risk assessment will be performed by the SMAQMD in order to determine the final status of the proposed soil aeration project. All soil aeration or soil excavation projects that are exempted from SMAQMD rules must submit a written proposal to the SMAQMD at least 7 working days before the proposed start date. All soil aeration/excavation proposals must include: i. The site address ii. The name of the property owner iii. The name of all contractors involved in the project iv. The estimated amount of soil to be aerated/excavated at the site v. The estimated amount of soil to be aerated per day (in cubic yards) XIX-3

vi. The type of contaminants in the soil vii. All lab analysis related to the contaminated soil viii. Emission rate calculations ix. Method of soil disposal x. And methods used to suppress fugitive emissions. Note: if the start or end dates change, the SMAQMD must receive a written notification of the new start/end date before the aeration process has started. The exposed surfaces of an excavated area will not be included in calculations that determine the volume of soil excavated. All inactive storage piles shall be kept covered with a continuous sheet of plastic 6 mils or thicker. Other material used to cover a storage pile will be considered on a case-by-case basis. All cover material seams must be sealed adequately enough to prevent fugitive emissions. Furthermore, all cover material must be securely anchored and have minimal headspace between the cover and the soil. Active storage piles shall have an exposed area only where work is being performed and must be covered immediately after work is completed or work on the pile is stopped for longer than 30 minutes. Upon approval of the proposal, permission to aerate/excavate the soil under the exemption will be granted. A permit shall be required for all other non-exempt soil aeration/excavation projects. d. All IC engines that are used to support a remediation system, that are 50 horsepower or less as determined by test procedure SAE J1349 or SAE J1995, and are not the control device shall be exempt from permitting requirements. 3. Permit Application Forms The following application forms must be completed and submitted by the applicant when applying for an Authority to Construct/Permit to Operate for any soil and/or groundwater remediation system equipment. These forms are used by the SMAQMD to characterize the type of process, size, flow rates, abatement devices, and exhaust stacks of the system. Form G100: Application for Authority to Construct and/or Permit to Operate Form G101: General Information Form HRA100: Health Risk Assessment Information The forms below must be completed for the appropriate equipment, as applicable: Form VI100: Vapor Incinerator/Afterburner Form CA100: Carbon Adsorption Unit Form ICE100: Internal Combustion Engines C. PERMIT APPLICATION COMPLETENESS A permit application is deemed complete with the submittal of the following information: 1. Completed permit application Forms G100, G101, HRA100, and any applicable forms listed in Section B3 above with the original signature of the owner/proprietor or responsible officer of the company. 2. Applicable initial permit fee (see Section D below). 3. Any additional information needed to perform a health risk assessment. 4. Soil concentration data from previous pilot testing or soil sampling. XIX-4

D. FEES The permit fee for each permit application is based on the applicable fee schedules of Rule 301. Fees may be adjusted annually. Please visit the SMAQMD website, www.airquality.org, for the most current version of forms and fee Rule 301. 1. New Units Soil Vapor Extraction / Groundwater Treatment Systems a. New installations or equipment not previously permitted: Use Schedule 1 (see Rule 301, Section 308.2). Fees are based on the rated horsepower of the electric blower motor. Use the Initial Permit Fee column for new installations or equipment not previously permitted. b. Systems using an IC engine as an emission control device and to drive a soil vapor extraction blower: Use Schedule 9 (see Rule 301, Section 308.10). 2. Modifications to the Soil Vapor Extraction / Groundwater Treatment System a. For modifications of permitted equipment resulting in an increase in the equipment horsepower, the fee is assessed in accordance with fee Schedule 1 (Rule 301, Section 306.1). b. For modifications resulting in no increase in the equipment horsepower, the fee shall be based on Rule 301, Section 306.2. 3. Emission Control Devices a. Fuel-Fired Oxidizers/Incinerators: Use Schedule 2 (see Rule 301, Section 308.3). Fees are based on the rated fuel consumption of the equipment. Use the Initial Permit Fee column for new installations or equipment not previously permitted. b. Electric Oxidizers/Incinerators: Use Schedule 3 (see Rule 301, Section 308.4). Fees are based on the KW rating of the equipment. Use the Initial Permit Fee column for new installations or equipment not previously permitted. c. Carbon Adsorption Systems: Use Schedule 9 (see Rule 301, Section 308.10). Use the Initial Permit Fee column for new installations or equipment not previously permitted. d. Units using an IC engine for emission control and the engine does not drive the blower: Use Schedule 7 (see Rule 301, Section 308.8). Fees are based on the rated horsepower of the engine. Use the Initial Permit Fee column for new installations or equipment not previously permitted. e. Air Strippers: Use Schedule 9 (see Rule 301, Section 308.10). Use the Initial Permit Fee column for new installations or equipment not previously permitted. 4. Modifications to Emission Control Devices a. For modifications resulting in an increase in horsepower or rated energy input/output, the fee is assessed in accordance with fee Schedule 2, 3, or 7 (Rule 301, Sections 308.3, 308.4, or 308.8, respectively), whichever is applicable, based on the incremental increase in horsepower or rated energy input/output resulting from such change (see Rule 301, Section 306.1). b. For modifications resulting in no increase in horsepower or rated energy input/output, the fee shall be based on Rule 301, Section 306.2. 5. Equipment Installed Without an Authority to Construct a. As per Section 302.1 of Rule 301, any person installing/operating regulated equipment without obtaining a permit from the SMAQMD first, will be required to pay permit renewal back fees for each year of unpermitted operation, to a maximum of 3 years, in addition to the initial permit fee. XIX-5

6. Initial Source Test Observation Fees a. As per Section 311 of Rule 301, a source test observation and report evaluation fee shall be charged against the owner or operator of a source that requires an initial source test to be performed and observed, and the report to be evaluated by the SMAQMD. When multiple source tests are performed and the results submitted in one consolidated report, the initial source test fee shall apply to the first 10 hours of SMAQMD work. Each additional hour or portion thereof required for reviewing the source test shall be charged the time and materials labor rate established in Section 308.12 of Rule 301. E. REGULATIONS Remediation equipment operating within the jurisdiction of the SMAQMD may be subject to some or all of the following rules and regulations. The type of operation, size of source, potential to emit, and other factors will dictate which rules are appropriate for a particular remediation application. Other rules may also apply. 1. SMAQMD Rules and Regulations (please refer to the actual rules for applicability and compliance determinations): a. Rule 102 -- Circumvention: This rule makes it unlawful for a person to circumvent any applicable section of the SMAQMD rules and regulations. b. Rule 201 -- General Permit Requirements: This rule provides an orderly procedure for the review of new or modified sources of air pollution and operation of existing sources through the issuance of permits. c. Rule 202 -- New Source Review: The purpose of this Rule is to provide for the review of new and modified stationary sources of air pollution and to provide mechanisms, including emissions offsets and BACT, by which authorities to construct such sources may be granted without interfering with the attainment or maintenance of ambient air quality standards. d. Rule 207 -- Title V - Federal Operating Permit Program: This rule establishes an operating permit program consistent with the requirements of Title V of the 1990 Clean Air Act Amendments and 40 CFR, Part 70. e. Rule 209 -- Limiting Potential to Emit: The purpose of this rule is to eliminate the need for small stationary sources to obtain a Title V operating permit pursuant to Rule 207. f. Rule 210 -- Synthetic Minor Source Status: The purpose of this rule is to allow owner and operators of stationary sources that would otherwise be major stationary sources to request and accept enforceable emissions limits sufficient to maintain the facility's potential to emit below major source thresholds. XIX-6

g. Rule 214 -- Federal New Source Review: The purpose of this rule is to provide for the issuance of authorities to construct and permits to operate at new and modified major stationary air pollution sources and to provide mechanisms, including emission offsets, by which authorities to construct such sources may be granted without interfering with the attainment or maintenance of ambient air quality standards. h. Rule 217 -- Public Notice Requirement for Permits: The purpose of this rule is to provide an administrative mechanism for public notification and review of the issuance of authorities to construct and permits to operate at new and modified stationary air pollution sources. i. Rule 301 -- Permit Fees - Stationary Source: The purpose of this rule is to establish fees to be charged to owners/operators of a stationary source to obtain a permit. j. Rule 306 -- Air Toxics Fees: This rule establishes fees to be charged stationary sources subject to the Air Toxics "Hot Spot" Information and Assessment Act (H&S Code, 44300) k. Rule 401 -- Ringelmann Chart: This rule limits the discharge of air contaminants into the atmosphere by limiting visible emissions. l. Rule 402 -- Nuisance: The purpose of this rule is to protect the public's health and welfare from the emissions of air contaminants which constitute a nuisance. m. Rule 404 -- Particulate Matter: This rule limits the discharge of particulate matter into the atmosphere from any source in excess of 0.1 grains per dry standard cubic foot of gas. n. Rule 406 -- Specific Contaminants: This rule limits emissions of sulfur compounds and combustion contaminants through establishment of emission concentration limitations. o. Rule 420 -- Sulfur Content of Fuels: This rule limits the sulfur content of gaseous and liquid fuels. 2. State Requirements a. California Health & Safety Code, Part 6 (commencing with section 44300) -- Air Toxics "Hot Spots Information and Assessment Act of 1987: Facilities subject to this requirement must identify and quantify emissions of toxic air contaminants. Facilities posing a potential health risk to the public must prepare a health risk assessment, if required, notify the public, and implement a risk reduction plan. b. California Health & Safety Code 42301.6 -- Permit Approval: Powers & Duties of APCO: Prior to approving an application for a permit to construct or modify a source that emits hazardous air pollutants, in which the source is located within 1,000 feet from a school site, the SMAQMD must prepare a public notice. The notice must be sent to parents or guardians of children enrolled in any school located within 1/4 mile (1320 XIX-7

ft) of the source and to each address within a radius of 1,000 feet of the source at least 30 days prior to taking final action on the application. In addition, IC engines locating within 1,000 feet from a school will be required to reduce hazardous air pollutant emissions and their associated health risk to the maximum extent deemed practicable. This may include, but is not limited to, emissions limitations, stack height requirements, and hours of operation restrictions. Furthermore, the applicant is responsible for paying all public notification costs. 3. Federal Requirements a. 40 CFR Part 52.21 Prevention of Significant Deterioration of Air Quality (PSD): A new source or modification triggers PSD if: i. Its potential to emit any one pollutant is greater than 100 tons/year (if one of the 28 selected industrial categories, including utility plants, steel plants, refineries, boilers >250 MMBTU/hr heat input) or greater than 250 tons/year (all other categories); and ii. The project s contemporaneous emissions increase and net emissions increase for any pollutant is greater than the significance levels listed below: Pollutant Level of Significance (tons/year) CO 100 NOx 40 SOx 40 PM 25 PM10 15 PM2.5 Ozone 10 (PM2.5) or 40 (SO 2 ) or 40(NO) 40 of NOx or VOCs Lead 0.6 Fluorides 3 Sulfuric acid mist 7 H 2 S 10 Total reduced sulfur (including H 2 S) 10 Reduced sulfur compounds (including H 2 S) 10 Greenhouse Gases (CO2e) 75,000 b. 40 CFR Part 63, Subpart GGGGG National Emission Standards for Hazardous Air Pollutants: Site Remediation: Remediation activities are subject to this regulation if the remediation activities are co-located at major stationary sources that emit hazardous air pollutants (HAP) and meet the affected source definition specified for a source category that is regulated by another subpart under 40 CFR part 63 (MACT standards). Remediation activities XIX-8

at gas stations and remediation activities performed under the authority of CERCLA or RCRA are exempt from Subpart GGGGG. STANDARDS AND REQUIREMENTS The following standards and/or requirements must be met in order to obtain an Authority to Construct and/or a Permit to Operate: 1. SMAQMD Regulation 2 Permits a. Rule 202 New Source Review i. Best Available Control Technology (BACT) Section 301 requires a new emissions unit or modification of an existing emissions unit to apply BACT if the daily potential to emit meets or exceeds the levels specified in Section 302.1 and below: Pollutant Volatile Organic Compound, VOC Nitrogen Oxides, NOx Sulfur Oxides, SOx Particulate Matter, PM10 Particulate Matter, PM2.5 Carbon Monoxide, CO BACT Trigger Level 0 lb/day 0 lb/day 0 lb/day 0 lb/day 0 lb/day 550 lb/day ii. BACT is defined as the most effective emission control device, emission limit, or technique, which has been required or used for the type of equipment or process. BACT determinations for soil and groundwater remediation systems are the following and apply to both large emission sources (>10 lb/day) and small emission sources (<10 lb/day): (a) For VOC Emissions: BACT for remediation projects is defined as attainment of set VOC control efficiencies corresponding to set influent concentration values (unless effluent VOC concentrations are less than 10 ppmv), as shown below: XIX-9

For VOC Concentration at Influent of Control Device (ppmv): For VOC Concentration at Effluent of Control Device (ppmv): VOC BACT for Soil and Groundwater Remediation: Required VOC Control Efficiency (A) N/A <10 ppmv None >2,000 ppmv N/A >98.5% >200 ppmv to <2,000 ppmv N/A >97% <200 ppmv N/A >90% Maximum Effluent VOC Daily Limit (B) 9.9 lb/day Typical VOC Control Technology (C) 1. Catalytic Oxidizers 2. Thermal Oxidizers 3. Carbon Adsorption 4. IC Engines (A) Based on Bay Area AQMD s BACT determination for Soil Vapor Extraction as Achieved in Practice (6-16-1995). (B) Based on the daily VOC limit that has been achieved in practice in the SMAQMD. (C) Catalytic oxidizers and thermal oxidizers shall be equipped with continuous temperature monitoring equipment and carbon adsorption systems shall perform monthly carbon breakthrough monitoring to ensure that BACT destruction efficiencies are met. (b) For NOx, SOx, PM10, PM2.5, and CO Emissions: Air pollution control devices for VOC emissions from soil and groundwater remediation systems may emit secondary criteria pollutant emissions of NOx, SOx, PM10, PM2.5, and CO, but since the emission source is an air pollution control device for VOC emissions, BACT does not apply. iii. Emission Offsets Section 302 requires that applicants provide emissions offsets for new or modified stationary sources where the cumulative emission increase for the facility exceeds the following levels: Pollutant Pounds/Quarter Volatile Organic Compounds (VOC) 5,000 Nitrogen Oxides (NOx) 5,000 Sulfur Oxides (SOx) 13,650 PM10 7,300 PM2.5 15 TPY Carbon Monoxide (CO) 49,500 XIX-10

b. Rule 217 Public Notice Requirements for Permits Prior to approving and Authority to Construct application for a new or modified stationary source or emissions unit which has an increase in potential to emit exceeding any of the following limits or where emission offsets are required pursuant to Rule 202, the District must submit a preliminary decision to CARB and EPA for review and publish the preliminary decision soliciting public review and comment at least 30 days prior to final action on the application. Pollutant Pounds/Quarter Volatile Organic Compounds (VOC) 5,000 Nitrogen Oxides (NOx) 5,000 Sulfur Oxides (SOx) 9,200 PM10 7,300 PM2.5 10 TPY Carbon Monoxide (CO) 49,500 2. SMAQMD Regulation 4 Prohibitory Rules a. Rule 401, Section 301: Visible emissions may not exceed No. 1 on the Ringelmann Chart or 20% opacity for more than three minutes in any one hour. b. Rule 402, Section 301: A person cannot discharge pollutants which cause injury, detriment, nuisance or annoyance to any considerable number of persons or which endanger the comfort, repose, health or safety of any such person, or which may cause damage to business or property (see Nuisance - Public Health section below). c. Rule 404, Section 301: A person shall not discharge into the atmosphere from any source particulate matter in excess of 0.23 grams per dry standard cubic meter (0.1 grains per dry standard cubic foot). d. Rule 406, Section 302: i. Combustion contaminant concentration at point of discharge shall not exceed 0.1 grains per dry standard cubic foot of gas, corrected to 12% carbon dioxide. ii. Sulfur compounds in any state or combination thereof at the point of discharge shall not exceed 0.2% by volume, calculated as sulfur dioxide (SO 2 ). e. Rule 420, Section 301: i. The sulfur content of gaseous fuels shall not exceed 50 grains per 100 cubic feet of gaseous fuel calculated as hydrogen sulfide at standard conditions. ii. The sulfur content of liquid or solid fuels shall not exceed a sulfur content of 0.5% by weight. Standard CARB diesel fuel complies with this requirement at 0.0015% sulfur by weight (typically not expected to be used as a fuel source). XIX-11

3. Nuisance Toxics Review and Toxics Best Available Control Technology (T-BACT) a. Toxics Review: Based on SMAQMD Rule 402 Nuisance, the SMAQMD evaluates the impact of a facility's toxic emissions project using the SMAQMD s guidance document, Health Risk Management Programs for Existing, Modified and New Stationary Sources. The action levels are summarized below. Please refer to the actual guidance document for more detail on how to calculate and interpret health risk: Cancer Risk: Excess Cancer Risk 0.1 per million Action Required Exempt from further toxic review. > 0.1 per million but 1 per million No significant risk; No action required. > 1 per million but 10 per million Acceptable risk; Provide T-BACT > 10 per million but 100 per million Permit denied unless the APCO makes a finding that not approving the project may result in a greater negative impact to the public than approving the project. > 100 per million Denial of permit. Non-Cancer Health Risk (Acute and Chronic): Hazard Index (HI) Action Required HI < 1 HI 1 Health risk is within acceptable range Consult OEHHA for further guidance When evaluating the cancer and non-cancer risks, the specific toxic air pollutants that need to be addressed are those that have potency values or reference exposure levels identified in the OEHHA s Health Risk Assessment Guidelines (http://www.oehha.ca.gov/air/hot_spots/index.html). b. Toxics Best Available Control Technology (T-BACT): T-BACT is similar to BACT, but applies to any new or modified source of toxic air pollutants which have health risks that exceed the specified levels above. Since the toxic pollutants of concern from soil and groundwater remediation (typically, TPHg, benzene, MtBE, perchloroethylene) are VOCs, the T-BACT determination for soil and groundwater remediation will be similar to the BACT determination, as follows: Pollutant T-BACT for Soil and Groundwater Remediation Catalytic Oxidizers Volatile Organic Compound, VOC Thermal Oxidizers Carbon Adsorption IC engines XIX-12

4. California Environmental Quality Act (CEQA) The SMAQMD has developed a comprehensive permitting CEQA Guidance document. Project reviews conducted in accordance with the policy manuals contained therein (including this manual) have been determined to meet the CEQA criteria of ministerial and do not require additional CEQA review. In the event a project falls outside the scope of this policy manual (for example a new BACT determination or other situation already described within the CEQA guidance document), the project shall follow the steps for CEQA review as detailed in the guidance document. 5. Other Standards Direct Venting Without a Control Device In the case where a remediation system has been permitted to operate by the SMAQMD and the influent concentrations to the emission control device drop to the levels indicated below, the applicant may submit a modification application to remove the control device and vent directly to ambient air. a. Daily total uncontrolled VOC emissions from the removal of a control device does not result in a daily emissions increase requiring BACT. The daily emissions increase shall be calculated as the daily Potential to Emit minus the daily Historic Potential Emissions (Rule 202, Section 413.2). b. Total uncontrolled VOC emissions are less than 9.9 lbs/day based on at least three consecutive months of source test data. (However, it is recommended that six consecutive months or more of source test data be collected to ensure seasonal factors do not result in a VOC emissions rebound.) c. The facility-wide excess cancer risk to the maximum impacted receptors is less than or equal to 1 in one million due to any uncontrolled emissions that have been identified as toxic air contaminants. d. The facility-wide excess non-cancer hazard index to the maximum impacted receptors is less than or equal to 1 due to any uncontrolled emissions that have been identified as toxic air contaminants. 6. Requirements for Uncontrolled Soil Aeration All contaminated soil excavation, soil stockpiling, soil bioremediation, soil stabilization and all other types of soil remediation projects are required to obtain a permit unless the Air Pollution Control Officer issues a written exemption letter. A soil aeration project will require a permit and public health screen if the project is not exempt as defined in the exemption section of this document. For permitted soil aeration projects, TPHg and benzene emission rates will be estimated using the following factors: a. The average TPHg or benzene concentration found by sampling and analysis of the soil stockpile. b. Five days of aeration. c. The total volume of soil in cubic yards. d. A soil density of 3,900 in lb/cy. XIX-13

The TPHg emission rate for uncontrolled aeration shall not exceed 50 lb/day. If the emission rate is above 50 lb/day or if the public health risk assessment from any carcinogenic compound is unacceptable, then more stringent BACT or T-BACT shall be applied. A person shall not aerate contaminated soil in excess of that specified in the table below. The limitations in the table below apply to the entire facility, and indicate the volume of contaminated soil that may be aerated uncontrolled. Any more soil to be added to the soil already aerating must receive prior written approval from the SMAQMD. REQUIREMENTS FOR UNCONTROLLED SOIL AERATION TABLE TPHg ppm (weight) Volume of Soil (cubic yards) <50 Exempt 50-99 600 100-499 120 500-999 60 1000-1999 30 2000-2999 15 3000-3999 10 4000-4999 8 >5000 0.1 Controlled Aeration: soil may be aerated at volumes exceeding the limitations in the above table provided emissions of TPHg to the atmosphere are reduced by at least 95% by weight and the results of the public health risk assessment is found to be acceptable. NOTE: Contaminated soil stockpiles shall be kept completely and securely covered at all times. 7. IC Engine Requirements An IC engine that operates as a control device is required to obtain an Authority to Construct/Permit to Operate unless the engine is rated at less than 50 hp and it operates at the site for less than 5 calendar days. 8. Ozone Remediation Systems Please contact the SMAQMD regarding the installation and operation of an ozone remediation system. XIX-14

G. CALCULATING EMISSIONS The sample calculations listed below show a method to calculate the volume flow rates and mass emission rates for a soil vapor extraction system with an emission control device. The applicant may use other methods as long as the results are comparable. 1. Volume Flow Rate Calculations for Natural Gas Oxidizers It is preferred to measure the stack effluent volume flow rate directly. However, the total effluent volume flow rate for oxidizers and IC engines may need to be calculated. Therefore, the following formulas are an acceptable alternative. For systems that must meet a control efficiency, the influent and effluent mass emission rates can be calculated using this method below. The effluent volume flow rate in SCFM may be calculated based on field measurements obtained from the combined well flow rate, dilution airflow, combustion airflow (if applicable), and the supplemental natural gas or propane flow rate (if applicable). Sum all influent flow rates to obtain the total effluent flow rate as follows: Sample field measurements: Influent well vapor temperature: 85 F Dilution air temperature: 70 F Natural gas temperature: 68 F Well flow rate: 65 ACFM Dilution airflow rate: 30 ACFM Natural gas flow rate: 3 SCFM Combustion airflow rate: 70 SCFM (as specified by the manufacturer) a. Correct to standard temperature of 68 F for each flow measurement as follows: Well flow rate of 65 ACFM at 85 F: SC M AC M 0 0. SC M (Formula assumes the pressure differential is insignificant) b. Dilution airflow measured as 30 ACFM at 70 degrees: SC M 0 AC M 0 0 0. SC M c. Natural gas flow: 3 SCFM (already at standard temperature) d. Maximum Combustion Air Blower Capacity: 70 SCFM e. Effluent volume flow rate in SCFM (sum of the above flow rates): 62.97 + 29.9 + 3 + 70 = 165.87 SCFM, Total flow of stack effluent f. Flow rate conversion SCFM to m 3 /day: SC M 0 min hour hour day m. 1 feet,. m day XIX-15

Note: For Carbon Adsorption Systems the effluent volume flow rate may be measured directly in most cases due to low temperatures in the stack. 2. Mass Emission Rate Calculations The following formula can be used to determine the mass emission rate (lb/day) from a measured concentration (ppm): Q c = (C c) * (F) * (MW c ) * (60 minutes/hour) * (24 hours/day) (10 6 ) * (V) where: Q c = Mass Emission Rate of Contaminant c, lbs/day C c = Concentration of Contaminant c, ppmv F = Vapor Volume Flow Rate, SCFM 10 6 = Conversion from parts per million to parts per unit volume V = Molar Volume = 385.3 ft 3 /lb-mol (based on Ideal Gas Law for a gas at standard conditions of 68 F and 1 atm) MW c = Molecular Weight of Contaminant c Molecular weights for common chemicals: TPHg (Weathered gasoline): Benzene: MtBE: Trichloroethylene (TCE): Ethylene Dichloride (1,2-Dichloroethane): Tetrachloroethylene (Perchloroethylene, PCE): Chloroform: Vinyl Chloride: Methylene Chloride: 100 lb/lb-mol 78.11 lb/lb-mol 88.15 lb/lb-mol 131.4 lb/lb-mol 98.96 lb/lb-mol 165.8 lb/lb-mol 119.4 lb/lb-mol 62.5 lb/lb-mol 84.93 lb/lb-mol Sample concentration and field measurements: TPHg concentration, C c = 280 ppmv Flow Rate, F = 165.77 SCFM Molar Volume, V = 385.3 ft 3 /lb-mol (based on Ideal Gas Law for a gas at standard conditions of 68 F and 1 atm) Molecular Weight of TPHg, MW c = 100 lb/lb-mol Using the given concentration and flow rate, the mass emission rate is calculated as follows: Q c = (280 ppmv) * (165.77 SCFM) * (100 g/mol) * (60 min/hr) * (24 hr/day) (10 6 ) * (385.3 ft 3 /lb-mol) Q c = 17.3 lb/day TPHg XIX-16

3. Combustion Emissions from Natural Gas Fired Thermal Oxidizers The following emission factors can be applied to natural gas fired thermal oxidizers: Pollutant VOC NOx SOx PM10 or PM2.5 (C) Emission Factor (A) N/A (B) 100 0.6 7.6 84 (lb/mmcf) (A) Emission factors for NOx, SOx, PM10, and CO are obtained from AP-42, Table 1.4-1 and1.4-2 (7/98). (B) Based on the daily VOC limit that has been achieved in practice in the SMAQMD. (C) AP-42, Table 1.4-2 indicates that since particulate matter emissions were assumed to be less than 1 micrometer in diameter, this emission factor may be used to estimate PM10 or PM2.5. 4. Greenhouse Gas (GHG) Emissions a. Soil and Groundwater Remediation Systems GHG emissions are not expected from soil and groundwater remediation systems. b. Natural Gas Fired Thermal Oxidizers The following emission factor can be used to calculate GHG emissions from natural gas fired thermal oxidizers: CO (A) Emission Factor for Natural Gas Combustion GHG CO 2 e (A) 117.00 lb CO 2 e/mmbtu Natural Gas GHG emission factor is the CO 2 e emission factor as per Tables C1 and C2 of Subpart C of EPA s Mandatory Reporting for Greenhouse Gases rule (40 CFR, Part 98). c. Electric Catalytic Oxidizers GHG emissions are not expected from electric catalytic oxidizers. d. Carbon Adsorption Systems GHG emissions are not expected from carbon adsorption systems. H. SOURCE TESTING/MONITORING The SMAQMD requires a compliance source test plan to be submitted to the SMAQMD 15 working days prior to the scheduled source test. The source test plan must be comprehensive enough to cover both the initial source tests and all subsequent source tests. In addition, summa canisters with a 30-minute regulator must be used for all initial and annual source tests. SMAQMD approval is required prior to implementation of the plan. 1. Source Test Plan The following procedures must be contained in a source test plan: A. A sample from the influent and effluent of the emission control device shall be collected via summa canisters with a minimum 30-minute regulator. XIX-17

B. The SOIL VAPOR EXTRACTION FIELD DATA SHEET form (available at www.airquality.org) shall be completed for each source test, or the following information shall be recorded: 1) Applicable operational parameters listed in Table 1, recorded every 15 minutes or per an approved duration, 2) Hour meter readings for each sample event, 3) Date and time of samples taken, 4) Date and time of any measurements or readings taken, including PID/FID readings, and 5) Calibration date and calibration expiration date for PID/FID instruments and all other instruments used for gathering field data as listed in Table 1. C. Emission methods shall be those specified in Table 2 and shall be analyzed by a NELAP or ELAP certified laboratory listed at: http://www.cdph.ca.gov/certlic/labs/pages/elap.aspx). Other methods may be used providing the SMAQMD has approved the method in writing. D. Include the laboratory detection limits. All laboratory detection limits shall be in compliance with the permitted emission limits. E. All sampling and flow measurement ports shall be located according to EPA or CARB Test Method 1 and shall include a detailed diagram of the sampling equipment. F. Specify the sampling tubing material type. All tubing used for sampling shall be made of material that will not absorb vapors from or emit contaminants into the sample, and the length shall not hold more than 5% of the sample container volume. G. Specify in detail how the standard volume flow rate (SCFM) will be measured and calculated for the stack effluent, corrected to standard conditions (68 F and 1 atm). H. All instruments used in collecting samples and monitoring operation shall be of the type and calibrated according to Table 1. I. For carbon adsorption systems: Carbon breakthrough monitoring as specified in the Authority to Construct/Permit to Operate. Note: In the case of groundwater treatment systems, influent water samples will be required in most instances and air emission estimates will be determined assuming that all VOCs are stripped out of the water after the treatment system. XIX-18

2. Required Instrumentation The instrumentation listed below shall be permanently installed, unless otherwise approved by the SMAQMD, while the soil/groundwater remediation system is in operation: a. Process instrumentation to monitor the process parameters listed in Table 1. The instruments used to monitor the process parameters shall be of the type listed in Table 1. The use of any instrument not listed in this document shall be prohibited unless written approval has been given by the SMAQMD. All instruments used to monitor the process parameters shall be calibrated as specified in Table 1, installed and maintained according to manufacturer's recommendations, and permanently installed on the system unless otherwise authorized by the SMAQMD. b. Non-resettable hour meter that reads 9,999 or more and is connected to the blower circuit. c. For oxidizers: a device that records the combustion chamber temperature and/or catalyst temperature at all times during operation. XIX-19

Table 1 Test Parameters and Acceptable Test Equipment for Soil/Water Remediation Projects Parameters Equipment Calibration* Temperature Pressure/Vacuum Gas Flow Fluid Flow Thermometer, Thermocouple, Temperature Controller Temperature Recorder Magnahelics, Std. Pressure Gauges Averaging Pitot Tube, Orifice Meter, Turbine Flow Meter, Hot Wire Anemometer Rotameter or other equivalent device Calibrated initially against a known NIST traceable standard. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a known NIST traceable standard (if applicable). Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a standard pressure barometer or pressure device that is NIST certified. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. * The manufacturer s certificate of calibration is acceptable if the date of certification, calibration accuracy, and length of time the certification is valid are included on the certificate. In addition, instruments purchased within 6 months of being used to take measurements will be considered calibrated. However, dated purchase documentation must be provided. XIX-20

Table 2 Sampling and Analytical Methods Pollutant Sampling Methods Analytical Methods TPHg/VOC Benzene MtBE Trichloroethylene (TCE) Ethylene Dichloride (1,2-Dichloroethane) Tetrachloroethylene (Perchloroethylene, PCE) Chloroform Vinyl Chloride Methylene Chloride EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-3, EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B, CARB 410A/B EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 Please be advised that a Notice of Violation will be issued if emission levels are exceeded in all cases with the exception of obvious laboratory errors. Inspection of the proposed equipment in the presence of an SMAQMD inspector is required at the time of initial source testing and annual source testing. XIX-21

3. Initial Source Testing Requirements Upon start-up of the operation, there shall be at least two compliance source tests conducted seven operational days apart from each other. Vapor samples shall be obtained and analyzed for the influent and effluent of the control device in order to verify compliance with the emission limits and VOC control efficiencies of the permit. The initial compliance source test samples shall be analyzed for the pollutants of concern within the first 96 hours from the start-up of operation. If the applicant chooses to continue operation of the system before they receive the analytical results, they will be liable for any emission levels that are exceeded. If preliminary laboratory test results have not been received by the end of the 4th calendar day from start-up, then the system shall be shut down. In addition, if the system cannot demonstrate compliance with an emission limit or the control efficiency requirement of the permit conditions, then the system shall be shut down as soon as determining non-compliance. SMAQMD approval for start-up operation must be obtained for either of the aforementioned situations. Note: The initial start-up period, as described above, is not exempt from the emission limitations specified by the permit or any applicable enforcement action, including the assessment of penalties. Acceptable sampling methods are listed in Table 2 unless otherwise approved by the Air Pollution Control Officer. 4. Ongoing Source Testing Requirements The sampling requirements and acceptable sampling equipment will be specified in the Authority to Construct/Permit to Operate. In the case of carbon adsorption control devices, vapor sampling/analysis may be required more frequently than for other pollution control devices to mitigate the risk of carbon breakthrough. However, carbon breakthrough monitoring shall be performed monthly to ensure that BACT destruction efficiencies are met, unless the SMAQMD grants written approval for an alternate monitoring frequency. 5. Carbon Breakthrough Monitoring For carbon adsorption systems, carbon breakthrough shall be monitored by the use of a Photo-Ionization Detector (PID), Flame-Ionization Detector (FID), or other method approved in writing by the Air Pollution Control Officer on a monthly basis, unless the SMAQMD grants written approval for an alternate monitoring frequency. 6. Reporting Requirements After completion of the initial compliance source tests, the applicant shall prepare and submit an initial emissions monitoring report documenting the results of the system sampling and analysis. This report must be submitted no later than 60 days after the second initial compliance source test date and shall include at least the following information (contained in the SOIL VAPOR EXTRACTION INITIAL EMISSIONS MONITORING REPORT form): A. An as built process flow diagram, which includes all of the sampling and flow measurement locations. B. Lab analysis results of each pollutant of concern as specified in the Authority to Construct/Permit to Operate summarized in a table format, which shall include the date, time, hour meter readings, and all process parameters recorded every 15 minutes. Include lab analysis reports and the lab detection limits as an attachment. XIX-22

C. All calculations, including mass emission rate calculations, shall be in units of lbs/day for each pollutant of concern. D. For effluent samples that have pollutant concentrations below the lab detection limit, the lab detection limit must be used as the pollutant concentration when calculating the system emission rate. E. Any additional information that describes any modifications or revisions to the system design including adjustments of the preliminary process parameters (i.e., temperature, flow rates, etc.). F. Serial numbers from the summa canisters used to collect samples. G. For carbon adsorption systems: Results of all carbon breakthrough analysis as specified in the Authority to Construct/Permit to Operate and using the SOIL VAPOR EXTRACTION CARBON BREAKTHROUGH MONITORING FORM. Sampling analysis must be performed by an independent, NELAP or ELAP certified laboratory to ensure compliance with SMAQMD Rules. The laboratory analysis report shall include all compounds that were detected for the specified test. For example, if test method EPA TO-15 was used, all detected compounds must be included in the report at the lowest detection limit for the test method. This applies to both influent and effluent samples. The SMAQMD shall be notified immediately after determining that the emission limits, the VOC control efficiency requirement, or the carbon breakthrough monitoring limits in the Authority to Construct/Permit to Operate are found to be in non-compliance. Refer to SMAQMD Rule 602 Breakdown Conditions: Emergency Variance for applicable breakdown procedures to determine if breakdown conditions apply. As specified in the Authority to Construct/Permit to Operate, the SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT shall be submitted to the SMAQMD within 30 days following the end of each calendar year. XIX-23

I. OVER-THE-COUNTER PERMITS Due to the need for a site-specific health risk assessment for each individual site, over-thecounter permits will not be granted for this source category. J. EXAMPLE ENGINEERING EVALUATION See Appendix XIX-A for a sample engineering evaluation for a soil vapor extraction system controlled by a natural gas fired thermal/catalytic oxidizer. See Appendix XIX-B for a sample engineering evaluation for a soil vapor extraction system controlled by a carbon adsorption system. K. EXAMPLE AUTHORITY TO CONSTRUCT See Appendix XIX-C for a sample Authority to Construct for a soil vapor extraction system controlled by a natural gas fired thermal/catalytic oxidizer. See Appendix XIX-D for a sample Authority to Construct for a soil vapor extraction system controlled by a carbon adsorption system. L. EXAMPLE PERMIT TO OPERATE See Appendix XIX-E for a sample Permit to Operate for a soil vapor extraction system controlled by a natural gas fired thermal/catalytic oxidizer. See Appendix XIX-F for a sample Permit to Operate for a soil vapor extraction system controlled by a carbon adsorption system. XIX-24

Exhibit XIX-A Sample Engineering Evaluation Soil Vapor Extraction System Using Natural Gas Fired Thermal/Catalytic Oxidizer Exhibit XIX-A

777 12th Street, 3rd Floor SACRAMENTO METROPOLITAN Sacramento, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT EVALUATION FACILITY NAME: COMPANY NAME APPLICATION NO.: App # DATE: EVALUATED BY: LOCATION OF EQUIPMENT: LOCATION ADDRESS, CITY, STATE ZIP CODE Date Name PROPOSAL: OPERATE A NEW SOIL VAPOR EXTRACTION SYSTEM UTILIZING A THERMAL/CATALYTIC OXIDIZER AT THE ABOVE SITE FOR THE CONTROL OF VOC EMISSIONS INTRODUCTION: COMPANY NAME was a former retail gasoline dispensing facility. The purpose of this proposal is to operate a soil vapor extraction (SVE) system and a thermal/catalytic oxidizer (or thermal oxidizer or electric catalytic oxidizer) to extract TPHg (VOC), benzene and MtBE from the contaminated area in order to clean up the soil. EQUIPMENT DESCRIPTION: The proposed remediation system consists of (specify number of wells only if source of contamination is other than typical gasoline or perchloroethylene) vapor extraction wells connected by a manifold to a 7.5 HP blower designed to extract a maximum volume flow rate of 350 scfm (add if applicable: and a dilution air blower designed to extract a maximum volume flow rate of 75 scfm, resulting in a total maximum system volume flow rate of 475 scfm). The SVE system will be vented to a 0.4 mmbtu/hr thermal/catalytic oxidizer for emission control. The stack parameters for the oxidizer are as follows: stack is 16 feet high by 20-inch diameter round exhaust, without a rain cap. (insert only for thermal/catalytic oxidizers): In catalytic mode, the minimum catalyst inlet temperature is 600 F, the minimum expected total stack flow rate is 225 scfm and the minimum expected stack temperature is 350 F, resulting in a minimum expected stack flow rate of. acfm calculate in SVE HRA Calcs spreadsheet. In thermal mode, the minimum oxidizer inlet temperature is 1,400 F, the minimum expected total stack flow rate is 225 scfm and the minimum expected stack temperature is 1,000 F, resulting in a minimum expected stack flow rate of. acfm calculate in SVE HRA Calcs spreadsheet).

Authority to Construct Evaluation A/C App # Date (insert only for catalytic oxidizers): The minimum catalyst inlet temperature is 600 F. The minimum expected total stack flow rate is 225 scfm and the minimum expected stack temperature is 350 F, resulting in a minimum expected stack flow rate of. acfm calculate in SVE HRA Calcs spreadsheet. (insert only for thermal oxidizers): The minimum oxidizer inlet temperature is 1,400 F. The minimum expected total stack flow rate is 225 scfm and the minimum expected stack temperature is 1,000 F, resulting in a minimum expected stack flow rate of. acfm calculate in SVE HRA Calcs spreadsheet. PROCESS RATE/FUEL USAGE: (insert only for thermal/catalytic oxidizers or thermal oxidizers): Natural Gas Fuel Usage (A) Equipment cf/hour cf/day cf/quarter cf/year Thermal/Catalytic Oxidizer 400 9,600 883,200 3,504,000 (A) Assuming a natural gas HHV of 1,000 BTU/cf and 24 hours/day, 92 days/quarter, and 365 days/year of operation. OPERATING SCHEDULE: The proposed operation schedule is 24 hours/day, 92 days/quarter and 365 days/year. CONTROL EQUIPMENT EVALUATION: The emission control system consists of a Solleco TCAT350 thermal/catalytic oxidizer, natural gas fired with a maximum burner capacity of 400,000 BTU/hr. The oxidizer is capable of achieving at least 95% VOC destruction efficiency. EMISSIONS CALCULATIONS: 1. DAILY HISTORIC POTENTIAL TO EMIT: The equipment is being evaluated as a new emission unit; therefore it has zero historic potential to emit.

Authority to Construct Evaluation A/C App # Date 2. PROPOSED POTENTIAL TO EMIT: Emission Maximum Allowable Emissions (B) Pollutant Factors (A) (lb/mmcf) lb/day lb/quarter lb/year VOC N/A 9.9 911 3,614 NOx 100 1.0 88 350 SOx 0.6 0.01 1 2 PM10 7.6 0.1 7 27 PM2.5 7.6 0.1 7 27 CO 84 0.8 74 294 Benzene N/A 0.019 N/A N/A MtBE N/A 0.136 N/A N/A GHG 117,000 0.6 tons/day 52 tons/quarter 205 tons/year (A) Emission factors for NOx, SOx, PM10, and CO are from AP-42, Table 1.4-1 and 1.4-2 (7/98) for natural gas combustion. Emission factor for PM2.5 is the PM10 factor assuming all PM10 to be PM2.5. GHG emission factor is expressed as CO2e and is from EPA s Mandatory Reporting of Greenhouse Gases Rule R 0, Tables C- 1 & C-2. (B) The emission limit for VOC is based on the SMAQMD s VOC BACT limit. NOx, SOx, PM10, and CO emissions are based on the maximum rated capacity of 400 cf/hour, 24 hours/day, 92 days/quarter, and 365 days/year of operation, and the emission factors listed in this table. The benzene and MtBE emission limits are based on a health risk assessment using EPA s ISCST model.

Authority to Construct Evaluation A/C App # Date 3. CALCULATION OF BACT TRIGGER: NEI = (DPE DHPE) DPE (BACT) = Daily Potential Emissions DHPE = Daily Historic Potential Emissions or Daily Actual Emissions if no enforceable daily emissions limitation is present prior to modification. BACT Trigger Level (lb/day) Pollutant DPE (BACT) (lb/day) DHPE (lb/day) NEI (lb/day) VOC 9.9 0 9.9 >0 Yes Is BACT Required? NOx 1.0 0 1.0 >0 No SOx 0.01 0 0.01 >0 No PM10 0.1 0 0.1 >0 No PM2.5 0.1 0 0.1 >0 No CO 0.8 0 0.8 >550 No Lead N/A 0 0 >0 No Benzene 0.019 0 0.019 N/A No MtBE 0.136 0 0.136 N/A No 4. CALCULATION OF OFFSET TRIGGER FOR VOC AND NOx: Permit No. Emissions Unit VOC Stationary Source Potential to Emit (lb/quarter) A/C 99998 Soil Vapor Extraction 0 0 A/C 99999 Thermal/Catalytic Oxidizer 911 88 NOx Total 911 88 Trigger Level >5,000 >5,000

Authority to Construct Evaluation A/C App # Date 5. CALCULATION OF OFFSET TRIGGER FOR SOx, PM10 AND CO: Permit No. Emissions Unit Stationary Source Cumulative Emission Increase Since 01-01-77 (lb/quarter) SOx PM10 CO A/C 99998 Soil Vapor Extraction 0 0 0 A/C 99999 Thermal/Catalytic Oxidizer 1 7 74 Total 1 7 74 Trigger Level >13,650 >7,300 >49,500 6. CALCULATION OF OFFSET TRIGGER FOR PM2.5: Permit No. Emissions Unit Stationary Source Cumulative Emission Increase Since 01-01-77 (tons/year) PM2.5 A/C 99998 Soil Vapor Extraction 0 A/C 99999 Thermal/Catalytic Oxidizer 0.0135 Total 0.0135 Trigger Level >15 7. CALCULATION OF EMISSION OFFSETS FOR VOC AND NOx: Emission offsets are not required for VOC or NOx because emissions are below the offset threshold. 8. CALCULATION OF EMISSION OFFSETS FOR SOx, PM10, PM2.5, AND CO: Emission offsets are not required for SOx, PM10, PM2.5, or CO because emissions are below the offset threshold. COMPLIANCE WITH RULES AND REGULATIONS: 1. H&S 42301.6 (AB 3205) COMPLIANCE: The emissions unit is not located within 1,000 feet from the outer boundary of any K-12 schools. Therefore the school public noticing requirements of CA Health & Safety Code 42301.6 do not apply.

Authority to Construct Evaluation A/C App # Date 2. NEW SOURCE REVIEW (NSR) COMPLIANCE: Rule 202 - New Source Review Section 301 - Best Available Control Technology The proposed potential to emit from the soil vapor extraction system exceeds the BACT threshold for VOC as specified in Section 301.1 and below. Therefore, BACT will be required for VOC. The thermal/catalytic oxidizer also emits secondary combustion emissions of NOx, SOx, PM10, PM2.5, and CO, but since the oxidizer is an air pollution control device for VOC emissions, BACT does not apply to the oxidizer. Pollutant _lb/day_ VOC 0 NOx 0 SOx 0 PM10 0 PM2.5 0 CO 550 Lead 3.3 In accordance with the SMAQMD Soil/Groundwater Remediation Permitting Procedures Manual, BACT for soil vapor extraction systems is defined as attainment of set VOC control efficiencies corresponding to set influent concentration values (unless effluent VOC concentrations are less than 10 ppmv), as shown below: For VOC Concentration at Influent of Control Device (ppmv): For VOC Concentration at Effluent of Control Device (ppmv): VOC BACT for Soil and Groundwater Remediation: Required VOC Control Efficiency (A) Maximum Effluent VOC Daily Limit (B) Typical VOC Control Technology (C) N/A <10 ppmv None 1. Catalytic Oxidizers >2,000 ppmv N/A >98.5% 2. Thermal 9.9 lb/day Oxidizers >200 ppmv to <2,000 ppmv N/A >97% 3. Carbon <200 ppmv N/A >90% Adsorption 4. IC Engines (A) Based on Bay Area AQMD s BACT determination for Soil Vapor Extraction as Achieved in Practice (6-16-1995). (B) Based on the daily VOC limit that has been achieved in practice in the SMAQMD. (C) Catalytic oxidizers and thermal oxidizers shall be equipped with continuous temperature monitoring equipment and carbon adsorption systems shall perform monthly carbon breakthrough monitoring to ensure that BACT destruction efficiencies are met.

Authority to Construct Evaluation A/C App # Date The applicant is proposing to use a thermal/catalytic oxidizer, which will be equipped with continuous temperature monitoring equipment and be required to conduct initial and annual VOC control efficiency testing to comply with BACT. Section 302 Offsets The cumulative emission increase for this stationary source does not meet or exceed the following levels of affected pollutant as specified in Section 302.1 and below. Therefore, emission offsets will not be required. Pollutant _lb/qtr_ VOC 5,000 NOx 5,000 SOx 13,650 PM10 7,300 PM2.5 15 TPY CO 49,500 Section 308 Denial, Failure to Meet CEQA The SMAQMD has developed a comprehensive permitting CEQA Guidance document. Project reviews conducted in accordance with the policy manuals contained therein have been determined to meet the CEQA criteria of ministerial and do not require additional CEQA review. This project falls within the scope of the SMAQMD Soil/Groundwater Remediation Permitting Procedures Manual and has been determined to be ministerial. No further review is required. Rule 214 Federal New Source Review This rule does not apply because this permit action is not for a new major stationary source or for a major modification at an existing major stationary source. Rule 217 Public Notification Requirements for Permits Sections 401-402 CARB, EPA, and Public Notification Emissions from this unit are not required to be offset pursuant to Rule 202, Section 302 and do not exceed the exemption level specified below. Therefore, pursuant to Section 110 of Rule 217, this permit action is exempt from the public notice requirements of Rule 217. _Pollutant lb/qtr_ VOC 5,000 NOx 5,000 SOx 9,200 PM10 7,300 PM2.5 10 TPY CO 49,500 3. PREVENTION OF SIGNIFICANT DETERIORATION (PSD) COMPLIANCE: A source or modification triggers PSD if: Its potential to emit any one pollutant is greater than 100 tons/year (if one of the 28 selected industrial categories, including utility plants, steel plants, refineries, boilers >250 MMBtu/hr heat input) or greater than 250 tons/year (all other categories); and The project s contemporaneous emissions increase and net emissions increase for any pollutant is greater than the significance levels listed below:

Authority to Construct Evaluation A/C App # Date Pollutant Level of Significance (Tons/Yr) CO 100 NOx 40 SOx 40 PM 25 PM10 15 PM2.5 10 (PM2.5) or 40 (SO 2 ) or 40(NO) Ozone 40 of NOx or VOCs Lead 0.6 Fluorides 3 Sulfuric acid mist 7 H 2 S 10 Total reduced sulfur (including H 2 S) 10 Reduced sulfur compounds (including H 2 S) 10 Greenhouse Gases (CO2e) 75,000 A more detailed PSD analysis is not required because the contemporaneous emissions increases for all pollutants at the facility do not exceed any of the significance levels shown above. 4. PROHIBITORY RULES COMPLIANCE: Rule 401 Ringelmann Chart The proposed equipment is expected to comply with the Ringelmann No. 1 or 20% opacity requirement of this rule. Rule 402 Nuisance CANCER RISK ASSESSMENT The ISCST3 model was used to determine the ground level concentrations of benzene and MtBE from the source in the ambient air (the maximum impact point). The maximum ground level impact is used to show the risk of cancer. Residential excess cancer risk numbers are based on 70 years exposure. Non-residential excess cancer risk numbers are based on 8 hours/day, 5 days/week, and 40 years/70 year lifetime. Benzene and MtBE emissions from soil vapor extraction have been identified by the Office of Environmental Health Hazard Assessment (OEHHA) as a toxic air contaminant (TAC). Facilities emitting TACs are required by the District to meet Toxic Best Available Control Technology (T-BACT) requirements if the Maximum Excess Cancer Risk (MECR) exceeds 1.0 in a million. Additionally the Acute and Chronic Hazard Index, which takes into account non-cancer health risks, shall be less than one for the facility. The index is the ratio of the highest ground level concentration to the non-cancer chronic and acute reference exposure levels. Meteorological data averaged over a 5-year period will be used.

Authority to Construct Evaluation A/C App # Date (insert only for thermal/catalytic oxidizers): The proposed oxidizer is able to operate as a thermal oxidizer or a catalytic oxidizer, depending on the concentrations of the pollutants being extracted. Different stack flow rates and temperatures exist depending on which mode is selected. When the catalytic oxidizer mode is selected the minimum expected stack flow rate is 345.2 acfm at a minimum stack temperature of 350 F; when the thermal oxidizer mode is selected the minimum expected stack flow rate is 622.2 acfm at a minimum stack temperature of 1,000 F. Due to these different input parameters, two models were run to determine how the concentration of air pollutants varied from one mode to the other. Based on a comparison of the resulting concentrations and allowable emission limits, the catalytic oxidizer produced the highest annual ground level concentrations for residential and nonresidential parcels. Therefore, the input parameters for the catalytic oxidizer mode will be used to conduct the health risk assessment as it represents the worst case scenario and the most constraining emissions. Breathing Rate Factor (BRF) Explanation: A breathing rate factor adjustment is used in the risk calculations to account for changes in OEHHA breathing factors and receptor dosage slope equations. The OEHHA breathing guidance changes increase the unit risk factors by a maximum of 25%, so an adjustment factor of 1.25 is used to account for the change. The applicant supplied the following parameters used in the model run: Stack Height: 16 feet Stack Diameter: 20 inches Minimum Volumetric Flow Rate: 345.2 acfm Minimum Stack Gas Temperature: 350 F Nominal Emission Rate: 1.0 g/sec At the nominal emission rate, the maximum annual concentration outside of the applicant s parcel is. μg/m 3 on a residential property located approximately 81 feet SE of the source UTM Northing m :, Easting: 0 1 and 0.0 μg/m 3 on a non-residential property located approximately 67 feet NW of the source (UTM Northing (m): 4278770, Easting: 650832). Summary of all the maximum concentrations for various receptors can be found in Appendix A Health Risk Assessment. The following factors, formulas, and assumptions were taken into consideration in order to estimate the worst case excess cancer risk and chronic hazard index for the toxic pollutant: Risk = E C U R B Risk = Risk of developing cancer E = Acceptable Emission Rate in g/s C Annual concentration downwind of stack in μg/m 3 per 1 g/s emission rate U = Unit Risk Factor 0.0000 μg/m 3 ) -1 for Benzene 0.000000 μg/m 3 ) -1 for MtBE R = Residential/Non-residential Factor = 1.0 (Res), 0.136 (Non-res) B = Breathing Rate Factor = 1.25

Authority to Construct Evaluation A/C App # Date E C HI = I HI E C I = Hazard Index = Acceptable Emission Rate in g/s Annual concentration downwind of stack in μg/m 3 per 1 g/s emission rate Inhalation μg/m 3 ) = 1,300.0 for Acute and 60.0 for Chronic (Benzene) = 8,000.0 for Chronic (MtBE) To determine the maximum allowable emission rate that results in the highest MECR of 1.0 per million for all receptors, the Risk is set below 1.0 (0.94 based upon past permitting actions) and the variable E is found. Note that the risk is cumulative, based upon the impact from both benzene and MtBE emissions combined. Knowing that for benzene alone (with a higher unit risk factor) yields an unacceptable risk before an unacceptable hazard index, Risk will be the determining factor for an appropriate emission rate. The following equation can be used for the residential cumulative risk: Risk= C E U R B+C E U R B B B M M C = Annual concentration for a residential receptor per g/s emission rate. μg/m 3 )/(g/s) E = Allowable emission rates, g/s, for benzene (B) and MtBE (M) U = Unit Risk Factor 0.0000 μg/m 3 ) -1 for Benzene 0.000000 μg/m 3 ) -1 for MtBE R = Residential Factor = 1.0 B = Breathing Rate Factor = 1.25 Working backwards from a maximum acceptable risk of 0.94 in one million and setting a ratio of 1:7 for benzene emissions to MtBE emissions (based upon past permitting actions), the allowable emission rates for benzene and MtBE are 0.00010 g/s and 0.00071 g/s, respectively (0.019 lb/day and 0.136 lb/day). The risks associated with these emission rates are as follows: Receptor (Worst Case) Residential Non-residential TAC Benzene MtBE Total Benzene MtBE Total Excess Cancer Risk (Persons/million) 8.84E-01 5.55E-02 9.40E-01 4.52E-02 2.83E-03 4.80E-02

Alimentary Bone Cardiovascular Developmental Endocrine Eye Hematologic Immune Kidney Nervous Reproductive Respiratory Skin Alimentary Tract Cardiovascular Developmental Eye Hematologic Immune Nervous Reproductive Respiratory Skin Authority to Construct Evaluation A/C App # Date NON-CANCER RISK ASSESSMENT The chronic non-cancer health risk is determined by dividing the contaminant's annual average ambient air concentration (ug/m 3 ) by the reference exposure level in order to obtain the hazard index (HI). The acute non-cancer health risk is determined in a similar fashion except the one-hour maximum ambient air concentration is used in the equation and the BRF correction is not applied. In addition, each contaminant can affect different organs of the body and several compounds may affect common organs. Therefore, when there are multiple toxic compounds involved, the effects are additive for the common organs. The hazard index for the organs affected by this system is shown below: Target Organ Affects Acute (Residential) Toxic Air Pollutant Benzene 0 0 1.08E-3 0 0 0 0 1.08E-3 0 0 MtBE 0 0 0 0 0 0 0 0 0 0 Total 0 0 1.08E-3 0 0 0 0 1.08E-3 0 0 Toxic Air Pollutant Target Organ Affects Chronic (Residential) Benzene 0 0 0 4.07E-4 0 0 4.07E-4 0 0 4.07E-4 0 0 0 MtBE 2.13E-5 0 0 0 0 2.13E-5 0 0 2.13E-5 0 0 0 0 Total 2.13E-5 0 0 4.07E-4 0 2.13E-5 4.07E-4 0 2.13E-5 4.07E-4 0 0 0

Alimentary Bone Cardiovascular Developmental Endocrine Eye Hematologic Immune Kidney Nervous Reproductive Respiratory Skin Alimentary Tract Cardiovascular Developmental Eye Hematologic Immune Nervous Reproductive Respiratory Skin Authority to Construct Evaluation A/C App # Date Target Organ Affects Acute (Non-Residential) Toxic Air Pollutant Benzene 0 0 1.34E-4 0 0 0 0 1.34E-4 0 0 MtBE 0 0 0 0 0 0 0 0 0 0 Total 0 0 1.34E-4 0 0 0 0 1.34E-4 0 0 Toxic Air Pollutant Target Organ Affects Chronic (Non-Residential) Benzene 0 0 0 1.53E-4 0 0 1.53E-4 0 0 1.53E-4 0 0 0 MtBE 8.01E-6 0 0 0 0 8.01E-6 0 0 8.01E-6 0 0 0 0 Total 8.01E-6 0 0 1.53E-4 0 8.01E-6 1.53E-4 0 8.01E-6 1.53E-4 0 0 0 The SMAQMD considers a non-carcinogenic health risk to be significant when the HI number exceeds one. This project has a combined HI number of less than one for both the acute and the chronic non-cancer health risk. A list of chronic or acutely hazardous air contaminants may be found at the OEHHA website www.oehha.ca.gov. The method of calculating the HI numbers (Risk Assessment Guidelines) is also found at this website. The health risk for this project is considered acceptable to the SMAQMD because the Excess Cancer Risk for the facility does not exceed 1.0 in 1 million and the noncancer Acute/Chronic Hazard Index is less than one for all cases. At the imposed emissions limits, T-BACT is not triggered. Furthermore, the ambient carcinogen concentrations calculated by the model as well as the calculation for the Excess Cancer Risk were estimated by using worst case scenario assumptions. Therefore, the Excess Cancer Risk calculated for the project represents the upper bound risk. The actual risk is expected to be less.

Authority to Construct Evaluation A/C App # Date (insert only for thermal oxidizers): Rule 404 Particulate Matter Total particulate matter emissions from the entire soil remediation system are expected to comply with the 0.1 gr/dscf concentration limitation of this rule, as calculated below: Grain Loading = [0.0042 lb/hr][7,000 gr/lb][1 hr/60 min] [225 CFM] = 0.00218 gr/cf (insert only for thermal oxidizers): Rule 406 - Specific Contaminants The proposed equipment is not expected to exceed the emissions limit of 0.2% by volume sulfur compound as SO 2 and 0.1 gr/dscf for combustion contaminants calculated to 12% CO 2. Natural Gas Fuel F-factor = 8,710 dscf/mmbtu at 0% O 2 Molar Volume = 385.3 ft 3 /mol Natural Gas HHV = 1,020 mmbtu/mmcf Conversion Factor = 7,000 gr/lb PM Emission Factor = 7.6 lb PM/mmcf SO 2 Emission Factor = 0.6 lb SO 2 /mmcf Natural Gas Fuel Density = 44,582 lb fuel/mmcf Weight % C in Natural Gas = 76 % or 0.76 lb C/lb fuel C to CO 2 Conversion Efficiency = 0.995 PM10 concentration (combustion contaminants): 1. Calculate uncorrected grain loading = (7.6 lb/mmcf) x (mmcf/1,020 mmbtu) x (7,000 gr/lb) x (mmbtu/8,710 dscf) = 0.005988159 gr/dscf 2. Calculate CO 2 emission factor (lb CO 2 /mmbtu) assuming 100% C to CO 2 conversion = (0.76 lb C/lb fuel) x (mol C/12 lb C) x (mol CO 2 /mol C) x (44 lb CO 2 /mol CO 2 ) x (44,582 lb fuel/mmcf) x (mmcf/1,020 mmbtu) = 121.7991895 lb CO 2 /mmbtu 3. Calculate lb CO 2 /mmbtu at 99.5% Conversion = 121.7991895 lb CO 2 /mmbtu x 99.5% = 121.1901936 lb CO 2 /mmbtu 4. Calculate volume % of CO 2 in Exhaust Gas = % CO 2 = mol CO 2 /mol exhaust = (121.1901936 lb CO 2 /mmbtu) x (mol CO 2 /44 lb CO 2 ) x (mmbtu/8,710 dscf) x (385.3 dscf/mol exhaust) = 0.121841618 mol CO 2 /mol exhaust or 12.1841618 % CO 2 5. Calculate corrected grain loading = (0.005988159 gr/dscf) x (12% CO 2 /12.1841618% CO 2 ) = 0.0059 gr/dscf corrected to 12% CO 2

Authority to Construct Evaluation A/C App # Date SO 2 Concentration (% SO 2 by volume): The following calculation is at 0% excess air which represents worst case. = (0.6 lb SO 2 /mmcf) x (mmcf/1,020 mmbtu) x (mmbtu/8,710 dscf) x (mol SO 2 /64 lb SO 2 ) x (385.3 dscf/mol exhaust) = 0.000000407 mol SO 2 /mol exhaust or 0.0000407 % SO 2 The rule emission limits for SO 2 and PM are 0.000023% SO 2 by volume and 0.003 grains/cf at 12% CO 2, respectively. Therefore, the emissions from the equipment comply with Rule 406. (insert only for thermal oxidizers): Rule 420 Sulfur Content of Fuels This rule limits the sulfur content of all gaseous fuels to less than 50 grains per 100 cubic foot, calculated as hydrogen sulfide (H 2 S). Pipeline natural gas in Sacramento County has a sulfur content of 0.22 grains per 100 cubic foot. Therefore, this equipment will comply with the requirement of this rule. 5. NEW SOURCE PERFORMANCE STANDARDS (NSPS) COMPLIANCE: NSPS under 40 CFR, Part 60: The list of all adopted New Source Performance Standards as listed in 40 CFR 60 (http://yosemite.epa.gov/r9/r9nsps.nsf/viewstandards?readform&part=60) were reviewed to determine if the proposed project is subject to one or more of these regulations. There are currently no NSPSs applicable to this source category. 6. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) COMPLIANCE: NESHAPs under 40 CFR, Part 61: The list of all adopted National Emission Standards for Hazardous Air Pollutants (http://yosemite.epa.gov/r9/r9nsps.nsf/viewstandards?readform&part=61) were reviewed to determine if the proposed project is subject to one or more of these regulations. There are currently no 40 CFR, Part 61 NESHAPs applicable to this source category. NESHAPs under 40 CFR, Part 63: The list of all adopted National Emission Standards for Hazardous Air Pollutants (http://yosemite.epa.gov/r9/r9nsps.nsf/viewstandards?readform&part=63) were reviewed to determine if the proposed project is subject to one or more of these regulations. There are currently no 40 CFR, Part 63 NESHAPs (MACT standards) applicable to this source category. For reference purposes, 40 CFR Part 63, Subpart GGGGG National Emission Standards for Hazardous Air Pollutants: Site Remediation will be discussed here. This subpart applies to remediation activities co-located at major stationary sources that emit hazardous air pollutants (HAP) and meet the affected source definition specified for a source category that is regulated by another subpart under 40 CFR Part 63 (another MACT standard). Remediation activities at gas stations and remediation activities performed under the authority of CERCLA or RCRA are exempt from this subpart. This project is not co-located at a major stationary source, and therefore this subpart is not applicable.

Authority to Construct Evaluation A/C App # Date 7. ATCM COMPLIANCE: The list of all adopted Airborne Toxic Control Measures (http://www.arb.ca.gov/toxics/atcm/atcm.htm) was reviewed to determine if the proposed project is subject to one or more of these regulations. There are currently no ATCMs applicable to this source category. RECOMMENDATION: The soil vapor extraction system and thermal/catalytic oxidizer should comply with all applicable District rules and regulations. An Authority to Construct a soil vapor extraction system and thermal/catalytic oxidizer should be issued to COMPANY NAME with the following conditions. Refer to conditions in Authority to Construct Nos. App # REVIEWED BY: Signature of reviewing Supervisor DATE: Date Review Approved

Exhibit XIX-B Sample Engineering Evaluation Soil Vapor Extraction System Using Carbon Adsorption System Exhibit XIX-B

777 12th Street, 3rd Floor SACRAMENTO METROPOLITAN Sacramento, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT EVALUATION FACILITY NAME: COMPANY NAME LOCATION OF EQUIPMENT: LOCATION ADDRESS, CITY, STATE ZIP CODE PROPOSAL: OPERATE A NEW SOIL VAPOR EXTRACTION SYSTEM UTILIZING A CARBON ADSORPTION SYSTEM AT THE ABOVE SITE FOR THE CONTROL OF VOC EMISSIONS INTRODUCTION: COMPANY NAME was a former dry cleaning facility. The purpose of this proposal is to operate a soil vapor extraction (SVE) system and a carbon adsorption system to extract VOC and perchloroethylene (PCE or tetrachloroethylene) from the contaminated area in order to clean up the soil. EQUIPMENT DESCRIPTION: The proposed remediation system consists of (specify number of wells only if source of contamination is other than typical gasoline or perchloroethylene) vapor extraction wells connected by a manifold to a 10 HP blower designed to extract a maximum volume flow rate of 250 scfm. The SVE system will be vented to a carbon adsorption system consisting of two 2,000-pound carbon units for emission control. The stack parameters for the carbon adsorption system are as follows: stack is 18 feet high by 4-inch diameter round exhaust, without a rain cap. The minimum expected stack flow rate is 150 scfm and the minimum expected stack temperature is 80 F, resulting in a minimum expected stack flow rate of 153.4 acfm (calculate in SVE HRA Calcs spreadsheet. PROCESS RATE/FUEL USAGE: Not applicable. OPERATING SCHEDULE: The proposed operation schedule is 24 hours/day, 92 days/quarter and 365 days/year. CONTROL EQUIPMENT EVALUATION: APPLICATION NO.: App # DATE: EVALUATED BY: Date Name The emission control system consists of a carbon adsorption system with two 2,000-pound carbon units in series. The carbon adsorption system is expected to achieve at least 95% VOC destruction efficiency.

Authority to Construct Evaluation A/C App # Date EMISSIONS CALCULATIONS: 1. DAILY HISTORIC POTENTIAL TO EMIT: The equipment is being evaluated as a new emission unit; therefore it has zero historic potential to emit. 2. PROPOSED POTENTIAL TO EMIT: Pollutant Emission Factors Maximum Allowable Emissions (A) lb/day lb/quarter lb/year VOC N/A 9.9 911 3,614 PCE N/A 0.049 N/A N/A GHG 0 0 tons/day 0 tons/quarter 0 tons/year (A) The emission limit for VOC is based on the SMAQMD s VOC BACT limit. The PCE emission limit is based on a health risk assessment using EPA s ISCST model. Emissions based on 24 hours/day, 92 days/quarter, and 365 days/year of operation. GHG emission factor is expressed as CO2e and is from EPA s Mandatory Reporting of Greenhouse Gases Rule (74 FR 56260), Tables C-1 & C-2. 3. CALCULATION OF BACT TRIGGER: NEI = (DPE DHPE) DPE (BACT) = Daily Potential Emissions DHPE = Daily Historic Potential Emissions or Daily Actual Emissions if no enforceable daily emissions limitation is present prior to modification. BACT Trigger Level (lb/day) Pollutant DPE (BACT) (lb/day) DHPE (lb/day) NEI (lb/day) VOC 9.9 0 9.9 >0 Yes Is BACT Required? NOx 0 0 0 >0 No SOx 0 0 0 >0 No PM10 0 0 0 >0 No PM2.5 0 0 0 >0 No CO 0 0 0 >550 No Lead 0 0 0 >0 No PCE 0.049 0 0.049 N/A No

Authority to Construct Evaluation A/C App # Date 4. CALCULATION OF OFFSET TRIGGER FOR VOC AND NOx: Permit No. Emissions Unit VOC Stationary Source Potential to Emit (lb/quarter) A/C 99998 Soil Vapor Extraction 911 0 A/C 99999 Carbon Adsorption System 0 0 Total 911 0 NOx Trigger Level >5,000 >5,000 5. CALCULATION OF OFFSET TRIGGER FOR SOx, PM10 AND CO: Permit No. Emissions Unit Stationary Source Cumulative Emission Increase Since 01-01-77 (lb/quarter) SOx PM10 CO A/C 99998 Soil Vapor Extraction 0 0 0 A/C 99999 Carbon Adsorption System 0 0 0 Total 0 0 0 Trigger Level >13,650 >7,300 >49,500 6. CALCULATION OF OFFSET TRIGGER FOR PM2.5: Permit No. Emissions Unit Stationary Source Cumulative Emission Increase Since 01-01-77 (tons/year) PM2.5 A/C 99998 Soil Vapor Extraction 0 A/C 99999 Carbon Adsorption System 0 Total 0 Trigger Level >15 7. CALCULATION OF EMISSION OFFSETS FOR VOC AND NOx: Emission offsets are not required for VOC or NOx because emissions are below the offset threshold. 8. CALCULATION OF EMISSION OFFSETS FOR SOx, PM10, PM2.5, AND CO: Emission offsets are not required for SOx, PM10, PM2.5, or CO because emissions are below the offset threshold.

Authority to Construct Evaluation A/C App # Date COMPLIANCE WITH RULES AND REGULATIONS: 1. H&S 42301.6 (AB 3205) COMPLIANCE: The emissions unit is not located within 1,000 feet from the outer boundary of any K-12 schools. Therefore the school public noticing requirements of CA Health & Safety Code 42301.6 do not apply. 2. NEW SOURCE REVIEW (NSR) COMPLIANCE: Rule 202 - New Source Review Section 301 - Best Available Control Technology The proposed potential to emit from the soil vapor extraction system exceeds the BACT threshold for VOC as specified in Section 301.1 and below. Therefore, BACT will be required for VOC. Pollutant _lb/day_ VOC 0 NOx 0 SOx 0 PM10 0 PM2.5 0 CO 550 Lead 3.3 In accordance with the SMAQMD Soil/Groundwater Remediation Permitting Procedures Manual, BACT for soil vapor extraction systems is defined as attainment of set VOC control efficiencies corresponding to set influent concentration values (unless effluent VOC concentrations are less than 10 ppmv), as shown below: For VOC Concentration at Influent of Control Device (ppmv): For VOC Concentration at Effluent of Control Device (ppmv): VOC BACT for Soil and Groundwater Remediation: Required VOC Control Efficiency (A) Maximum Effluent VOC Daily Limit (B) Typical VOC Control Technology (C) N/A <10 ppmv None 1. Catalytic Oxidizers >2,000 ppmv N/A >98.5% 2. Thermal 9.9 lb/day Oxidizers >200 ppmv to <2,000 ppmv N/A >97% 3. Carbon <200 ppmv N/A >90% Adsorption 4. IC Engines (A) Based on Bay Area AQMD s BACT determination for Soil Vapor Extraction as Achieved in Practice (6-16-1995). (B) Based on the daily VOC limit that has been achieved in practice in the SMAQMD. (C) Catalytic oxidizers and thermal oxidizers shall be equipped with continuous temperature monitoring equipment and carbon adsorption systems shall perform monthly carbon breakthrough monitoring to ensure that BACT destruction efficiencies are met.

Authority to Construct Evaluation A/C App # Date The applicant is proposing to use a carbon adsorption system, which will be required to perform monthly carbon breakthrough monitoring and initial and annual VOC control efficiency testing to comply with BACT. Section 302 Offsets The cumulative emission increase for this stationary source does not meet or exceed the following levels of affected pollutant as specified in Section 302.1 and below. Therefore, emission offsets will not be required. Pollutant _lb/qtr_ VOC 5,000 NOx 5,000 SOx 13,650 PM10 7,300 PM2.5 15 TPY CO 49,500 Section 308 Denial, Failure to Meet CEQA The SMAQMD has developed a comprehensive permitting CEQA Guidance document. Project reviews conducted in accordance with the policy manuals contained therein have been determined to meet the CEQA criteria of ministerial and do not require additional CEQA review. This project falls within the scope of the SMAQMD Soil/Groundwater Remediation Permitting Procedures Manual and has been determined to be ministerial. No further review is required. Rule 214 Federal New Source Review This rule does not apply because this permit action is not for a new major stationary source or for a major modification at an existing major stationary source. Rule 217 Public Notification Requirements for Permits Sections 401-402 CARB, EPA, and Public Notification Emissions from this unit are not required to be offset pursuant to Rule 202, Section 302 and do not exceed the exemption level specified below. Therefore, pursuant to Section 110 of Rule 217, this permit action is exempt from the public notice requirements of Rule 217. _Pollutant lb/qtr_ VOC 5,000 NOx 5,000 SOx 9,200 PM10 7,300 PM2.5 10 TPY CO 49,500 3. PREVENTION OF SIGNIFICANT DETERIORATION (PSD) COMPLIANCE: A source or modification triggers PSD if: Its potential to emit any one pollutant is greater than 100 tons/year (if one of the 28 selected industrial categories, including utility plants, steel plants, refineries, boilers >250 MMBtu/hr heat input) or greater than 250 tons/year (all other categories); and The project s contemporaneous emissions increase and net emissions increase for any pollutant is greater than the significance levels listed below:

Authority to Construct Evaluation A/C App # Date Pollutant Level of Significance (Tons/Yr) CO 100 NOx 40 SOx 40 PM 25 PM10 15 PM2.5 10 (PM2.5) or 40 (SO 2 ) or 40(NO) Ozone 40 of NOx or VOCs Lead 0.6 Fluorides 3 Sulfuric acid mist 7 H 2 S 10 Total reduced sulfur (including H 2 S) 10 Reduced sulfur compounds (including H 2 S) 10 Greenhouse Gases (CO2e) 75,000 A more detailed PSD analysis is not required because the contemporaneous emissions increases for all pollutants at the facility do not exceed any of the significance levels shown above. 4. PROHIBITORY RULES COMPLIANCE: Rule 401 Ringelmann Chart The proposed equipment is expected to comply with the Ringelmann No. 1 or 20% opacity requirement of this rule. Rule 402 Nuisance CANCER RISK ASSESSMENT The ISCST3 model was used to determine the ground level concentrations of PCE from the source in the ambient air (the maximum impact point). The maximum ground level impact is used to show the risk of cancer. Residential excess cancer risk numbers are based on 70 years exposure. Non-residential excess cancer risk numbers are based on 8 hours/day, 5 days/week, and 40 years/70 year lifetime. PCE emissions from soil vapor extraction have been identified by the Office of Environmental Health Hazard Assessment (OEHHA) as a toxic air contaminant (TAC). Facilities emitting TACs are required by the District to meet Toxic Best Available Control Technology (T-BACT) requirements if the Maximum Excess Cancer Risk (MECR) exceeds 1.0 in a million. Additionally the Acute and Chronic Hazard Index, which takes into account non-cancer health risks, shall be less than one for the facility. The index is the ratio of the highest ground level concentration to the non-cancer chronic and acute reference exposure levels. Meteorological data averaged over a 5-year period will be used.

Authority to Construct Evaluation A/C App # Date Breathing Rate Factor (BRF) Explanation: A breathing rate factor adjustment is used in the risk calculations to account for changes in OEHHA breathing factors and receptor dosage slope equations. The OEHHA breathing guidance changes increase the unit risk factors by a maximum of 25%, so an adjustment factor of 1.25 is used to account for the change. The applicant supplied the following parameters used in the model run: Stack Height: 18 feet Stack Diameter: 4 inches Minimum Volumetric Flow Rate: 153.4 acfm Minimum Stack Gas Temperature: 80 F Nominal Emission Rate: 1.0 g/sec At the nominal emission rate, the maximum annual concentration outside of the applicant s parcel is. μg/m 3 on a residential property located approximately 94 feet Ne of the source UTM Northing m : 0, Easting: 100 and 1. μg/m 3 on a non-residential property located approximately 80 feet NE of the source (UTM Northing (m): 4282690, Easting: 656106). Summary of all the maximum concentrations for various receptors can be found in Appendix A Health Risk Assessment. The following factors, formulas, and assumptions were taken into consideration in order to estimate the worst case excess cancer risk and chronic hazard index for the toxic pollutant: Risk = E C U R B Risk = Risk of developing cancer E = Acceptable Emission Rate in g/s C Annual concentration downwind of stack in μg/m 3 per 1 g/s emission rate U Unit Risk actor 0.00000 μg/m 3 ) -1 for Perchloroethylene R = Residential/Non-residential Factor = 1.0 (Res), 0.136 (Non-res) B = Breathing Rate Factor = 1.25 E C HI = I HI E C I = Hazard Index = Acceptable Emission Rate in g/s Annual concentration downwind of stack in μg/m 3 per 1 g/s emission rate Inhalation μg/m 3 ) = 20,000 for Acute and 35 for Chronic for Perchloroethylene To determine the maximum allowable emission rate that results in the highest MECR of 1.0 per million for all receptors, the Risk is set below 1.0 (0.94 based upon past permitting actions) and the variable E is found. Working backwards from a maximum acceptable risk of 0.94 in one million, the allowable emission rate for PCE is 0.00026 g/s (0.049 lb/day). The risks associated with this emission rate are as follows:

Alimentary Tract Cardiovascular Developmental Eye Hematologic Immune Nervous Reproductive Respiratory Skin Alimentary Bone Cardiovascular Developmental Endocrine Eye Hematologic Immune Kidney Nervous Reproductive Respiratory Skin Alimentary Tract Cardiovascular Developmental Eye Hematologic Immune Nervous Reproductive Respiratory Skin Authority to Construct Evaluation A/C App # Date Receptor (Worst Case) TAC Excess Cancer Risk (Persons/million) Residential PCE 9.40E-01 Non-residential PCE 4.38E-02 NON-CANCER RISK ASSESSMENT The chronic non-cancer health risk is determined by dividing the contaminant's annual average ambient air concentration (ug/m 3 ) by the reference exposure level in order to obtain the hazard index (HI). The acute non-cancer health risk is determined in a similar fashion except the one-hour maximum ambient air concentration is used in the equation and the BRF correction is not applied. In addition, each contaminant can affect different organs of the body and several compounds may affect common organs. Therefore, when there are multiple toxic compounds involved, the effects are additive for the common organs. The hazard index for the organs affected by this system is shown below: Target Organ Affects Acute (Residential) Toxic Air Pollutant PCE 0 0 0 1.81E-4 0 0 1.81E-4 0 1.81E-4 0 Toxic Air Pollutant Target Organ Affects Chronic (Residential) PCE 3.64E-3 0 0 0 0 0 0 0 3.64E-3 0 0 0 0 Target Organ Affects Acute (Non-Residential) Toxic Air Pollutant PCE 0 0 0 1.53E-4 0 0 1.53E-4 0 1.53E-4 0

Alimentary Bone Cardiovascular Developmental Endocrine Eye Hematologic Immune Kidney Nervous Reproductive Respiratory Skin Authority to Construct Evaluation A/C App # Date Target Organ Affects Chronic (Non-Residential) Toxic Air Pollutant PCE 1.25E-3 0 0 0 0 0 0 0 1.25E-3 0 0 0 0 The SMAQMD considers a non-carcinogenic health risk to be significant when the HI number exceeds one. This project has a combined HI number of less than one for both the acute and the chronic non-cancer health risk. A list of chronic or acutely hazardous air contaminants may be found at the OEHHA website www.oehha.ca.gov. The method of calculating the HI numbers (Risk Assessment Guidelines) is also found at this website. The health risk for this project is considered acceptable to the SMAQMD because the Excess Cancer Risk for the facility does not exceed 1.0 in 1 million and the noncancer Acute/Chronic Hazard Index is less than one for all cases. At the imposed emissions limits, T-BACT is not triggered. Furthermore, the ambient carcinogen concentrations calculated by the model as well as the calculation for the Excess Cancer Risk were estimated by using worst case scenario assumptions. Therefore, the Excess Cancer Risk calculated for the project represents the upper bound risk. The actual risk is expected to be less. 5. NEW SOURCE PERFORMANCE STANDARDS (NSPS) COMPLIANCE: NSPS under 40 CFR, Part 60: The list of all adopted New Source Performance Standards as listed in 40 CFR 60 (http://yosemite.epa.gov/r9/r9nsps.nsf/viewstandards?readform&part=60) were reviewed to determine if the proposed project is subject to one or more of these regulations. There are currently no NSPSs applicable to this source category. 6. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) COMPLIANCE: NESHAPs under 40 CFR, Part 61: The list of all adopted National Emission Standards for Hazardous Air Pollutants (http://yosemite.epa.gov/r9/r9nsps.nsf/viewstandards?readform&part=61) were reviewed to determine if the proposed project is subject to one or more of these regulations. There are currently no 40 CFR, Part 61 NESHAPs applicable to this source category. NESHAPs under 40 CFR, Part 63: The list of all adopted National Emission Standards for Hazardous Air Pollutants (http://yosemite.epa.gov/r9/r9nsps.nsf/viewstandards?readform&part=63) were reviewed to determine if the proposed project is subject to one or more of these regulations. There are currently no 40 CFR, Part 63 NESHAPs (MACT standards) applicable to this source category.

Authority to Construct Evaluation A/C App # Date For reference purposes, 40 CFR Part 63, Subpart GGGGG National Emission Standards for Hazardous Air Pollutants: Site Remediation will be discussed here. This subpart applies to remediation activities co-located at major stationary sources that emit hazardous air pollutants (HAP) and meet the affected source definition specified for a source category that is regulated by another subpart under 40 CFR Part 63 (another MACT standard). Remediation activities at gas stations and remediation activities performed under the authority of CERCLA or RCRA are exempt from this subpart. This project is not co-located at a major stationary source, and therefore this subpart is not applicable. 7. ATCM COMPLIANCE: The list of all adopted Airborne Toxic Control Measures (http://www.arb.ca.gov/toxics/atcm/atcm.htm) was reviewed to determine if the proposed project is subject to one or more of these regulations. There are currently no ATCMs applicable to this source category. RECOMMENDATION: The soil vapor extraction system and carbon adsorption system should comply with all applicable District rules and regulations. An Authority to Construct a soil vapor extraction system and carbon adsorption system should be issued to COMPANY NAME with the following conditions. Refer to conditions in Authority to Construct Nos. App # REVIEWED BY: Signature of reviewing Supervisor DATE: Date Review Approved

Exhibit XIX-C Sample Authority to Construct Soil Vapor Extraction System Using Natural Gas Fired Thermal/Catalytic Oxidizer Exhibit XIX-C

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT A/C NO.: 99998 & 99999 ISSUED BY: DATE ISSUED: MONTH DAY, YEAR PERMIT ENGINEER DATE EXPIRES: ISSUED TO: LOCATION: MONTH DAY, YEAR COMPANY NAME LOCATION ADDRESS, CITY, STATE ZIP PERMIT NO.: DESCRIPTION: 99998 SOIL VAPOR EXTRACTION SYSTEM: (specify number of soil vapor extraction wells only if source of contamination is other than typical gasoline or perchloroethylene: NUMBER OF VAPOR EXTRACTION WELLS: 5,) BLOWER RATING: 7.5 HP, SVE MAXIMUM RATED FLOW RATE: 350 SCFM, DILUTION BLOWER MAXIMUM RATED FLOW RATE: 75 SCFM, TOTAL SYSTEM MAXIMUM RATED FLOW RATE: 425 SCFM. 99999 APCD: THERMAL OXIDIZER, THERMAL/CATALYTIC OXIDIZER OR ELECTRIC CATALYTIC OXIDIZER FOR A/C 99998, MAKE: SOLLECO, MODEL: TCAT350, RATED HEAT INPUT: 0.4 MMBTU/HR, NATURAL GAS FIRED, STACK HEIGHT: 16 FEET, STACK DIAMETER: 20 INCHES WITHOUT RAIN CAP. START-UP REQUIREMENTS AUTHORITY TO CONSTRUCT CONDITIONS S1. Upon installation of the equipment authorized in this Authority to Construct, the owner/operator shall contact the Sacramento Metropolitan Air Quality Management District (SMAQMD) at (916) 874-4800 to arrange for a start-up inspection. S2. This Authority to Construct shall serve as a temporary Permit to Operate provided that: A. The SMAQMD has been notified to conduct a start-up inspection. B. The equipment installed matches the equipment authorized in this Authority to Construct. C. The equipment is operated in compliance with all conditions listed within this Authority to Construct. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT GENERAL 1. The equipment shall be properly maintained and operated in accordance with the manufacturer s recommendations at all times. 2. The Air Pollution Control Officer and/or authorized representatives, upon the presentation of credentials shall be permitted: A. To enter upon the premises where the source is located or in which any records are required to be kept under the terms and conditions of this Authority to Construct, and B. At reasonable times to have access to and copy any records required to be kept under terms and conditions of this Authority to Construct, and C. To inspect any equipment, operation, or method required in this Authority to Construct, and D. To sample emissions from the source or require samples to be taken. 3. This Authority to Construct does not authorize the emission of air contaminants in excess of those allowed by Division 26, Part 4, Chapter 3, of the California Health and Safety Code or the Rules and Regulations of the SMAQMD. 4. The equipment shall not discharge such quantities of air contaminants or other materials which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. [Basis: SMAQMD Rule 402, Section 301] 5. A legible copy of this Authority to Construct shall be maintained on the premises with the equipment. [Basis: SMAQMD Rule 201, Section 401] EMISSION LIMITATIONS 6. The soil vapor extraction system and thermal/catalytic oxidizer shall not discharge into the atmosphere any visible air contaminant other than uncombined water vapor for a period or periods aggregating more than three minutes in any one hour which is as dark or darker than Ringelmann No. 1 or equivalent to or greater than 20% opacity. [Basis: SMAQMD Rule 401, Section 301] 7. The emissions from the soil vapor extraction system and thermal/catalytic oxidizer shall not emit: A. VOC in excess of 9.9 lb/day. B. Benzene in excess of 0.019 lb/day. C. MtBE in excess of 0.136 lb/day. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT 8. The emissions from the soil vapor extraction system and thermal/catalytic oxidizer shall not exceed the following limits: [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] Pollutant Emission Factors (A) (lb/mmcf) Maximum Allowable Emissions (B) lb/day lb/quarter lb/year VOC N/A (C) 911 3,614 NOx 100 1.0 88 350 SOx 0.6 0.01 1 2 PM10 7.6 0.1 7 27 PM2.5 7.6 0.1 7 27 CO 84 0.8 74 294 Benzene N/A (C) N/A N/A MtBE N/A (C) N/A N/A GHG 117,000 0.6 tons/day 52 tons/quarter 205 tons/year (A) Emission factors for NOx, SOx, PM10, and CO are from AP-42, Table 1.4-1 and 1.4-2 (7/98) for natural gas combustion. Emission factor for PM2.5 is the PM10 factor assuming all PM10 to be PM2.5. GHG emission factor is expressed as CO2e and is from EPA s Mandatory Reporting of Greenhouse Gases Rule (74 FR 56260), Tables C-1 & C-2. (B) The emission limit for VOC is based on the SMAQMD s VOC BACT limit. NOx, SOx, PM10, and CO emissions are based on the maximum rated capacity of 400 cf/hour, 24 hours/day, 92 days/quarter, and 365 days/year of operation, and the emission factors listed in this table. The benzene and MtBE emission limits are based on a health risk assessment using EPA s ISCST model. (C) The daily emission limits for VOC, benzene, and MtBE are listed in Condition No. 7. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT 9. The thermal/catalytic oxidizer shall attain the following VOC control efficiency corresponding to the influent VOC concentration as measured according to Condition No. 17 (unless the effluent VOC concentration is 10 ppmv or less as measured according to Condition No. 17): [Basis: SMAQMD Rule 202, Section 301] If VOC Concentration at Influent of Control Device (ppmv) is: Or if VOC Concentration at Effluent of Control Device (ppmv) is: Then Required VOC Control Efficiency is: (A) N/A <10 ppmv None >2,000 ppmv N/A >98.5% >200 ppmv to <2,000 ppmv N/A >97% <200 ppmv N/A >90% (A) VOC control efficiency calculated in accordance with the SOIL VAPOR EXTRACTION INITIAL SOURCE TEST REPORT form (available at www.airquality.org). EQUIPMENT OPERATION 10. The thermal/catalytic oxidizer shall only be fueled by pipeline-quality natural gas. 11. The thermal/catalytic oxidizer will be operated at a combustion temperature of 600 F or higher while the soil vapor extraction system is operating in catalytic oxidizer mode and 1400 F or higher while the soil vapor extraction system is operating in thermal oxidizer mode. In addition, the thermal/catalytic oxidizer shall be equipped with a continuous combustion temperature recorder. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] 12. All soil vapor extraction wells shall be capped to prevent vapors from venting into the atmosphere when not connected to the control device. In addition, all dilution air valves and soil vapor extraction wells shall be closed when the control device is not operating. 13. The soil vapor extraction system shall have a functioning meter to measure the hours of operation. The meter shall read at least 9,999 hours. 14. The soil vapor extraction system shall be vented to a thermal/catalytic oxidizer during all operational periods, unless a written authorization is obtained from the Air Pollution Control Officer. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT 15. The emission control device may be removed and vented directly to ambient air upon written approval from the Air Pollution Control Officer and under the following conditions: A. A modification application and applicable fees to request removal of the emission control device shall be submitted to the SMAQMD for approval 30 calendar days in advance. B. Daily total uncontrolled VOC emissions from the removal of the emission control device does not result in a daily emissions increase requiring BACT, calculated as the daily Potential to emit minus the daily Historic Potential Emissions. C. Total uncontrolled VOC emissions are less than 2 lbs/day and less than or equal to 10 ppm based on at least 3 months of continuous test data. D. The maximum excess cancer risk to any offsite receptor is less than or equal to 1 in a million and the maximum acute and chronic Hazard Index is less than 1 due to any uncontrolled emissions that have been identified as toxic air contaminants. 16. The soil vapor extraction system will not be used to treat any halogenated compounds or chlorinated compounds or toxic compounds except benzene, MtBE, ethyl benzene, toluene, and xylenes. A. If any halogenated compounds or chlorinated compounds or other toxic compounds are detected, then within 15 days of the date of the lab analysis report: 1) A summa canister sample of the influent of the system shall be collected and analyzed in accordance with the procedure as the previous sample and the lab analysis results submitted to the SMAQMD, and 2) The system shall be shut down. B. If the system continues to show detection of halogenated compounds or chlorinated compounds, the system shall remain shut down and the owner/operator shall: 1) Within 30 days of the date of the 2 nd lab analysis report, conduct a source test of the effluent of the system for polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (PCDDs and PCDFs), or 2) Within 30 days of the lab analysis report, apply for an Authority to Construct/Permit to Operate a carbon adsorption system to replace or follow the thermal/catalytic oxidizer. C. If the system continues to show detection of other toxic compounds, the system shall remain shut down and be subject to reevaluation. A modification application and applicable fees may apply. D. SMAQMD approval must be obtained prior to restarting the system for operation. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT SOURCE TESTING REQUIREMENTS 17. Submittal of a source test plan 15 days prior to the initial source test is required for SMAQMD review and approval. This plan will be used for the initial source test and all subsequent tests to verify compliance with the emission limits in Condition No. 7 and the VOC control efficiency requirement in Condition No. 9. The source test shall be conducted in accordance with the following procedure: A. A sample from the influent and effluent of the emission control device shall be collected via summa canisters with a minimum 30-minute regulator. B. The SOIL VAPOR EXTRACTION FIELD DATA SHEET form (available at www.airquality.org) shall be completed for each source test, or the following information shall be recorded: 1) Applicable operational parameters listed in Table 1, recorded every 15 minutes or per an approved duration, 2) Hour meter readings for each sample event, 3) Date and time of samples taken, 4) Date and time of any measurements or readings taken, including PID/FID readings, and 5) Calibration date and calibration expiration date for PID/FID instruments and all other instruments used for gathering field data as listed in Table 1. C. Emission methods shall be those specified in Table 2 and shall be analyzed by a NELAP or ELAP certified laboratory. Other methods may be used providing the SMAQMD has approved the method in writing. D. Include the laboratory detection limits. All laboratory detection limits shall be in compliance with Condition No. 7. E. All sampling and flow measurement ports shall be located according to EPA or CARB Test Method 1 and shall include a detailed diagram of the sampling equipment. F. Specify the sampling tubing material type. All tubing used for sampling shall be made of material that will not absorb vapors from or emit contaminants into the sample, and the length shall not hold more than 5% of the sample container volume. G. Specify in detail how the standard volume flow rate (SCFM) will be measured and calculated for the stack effluent, corrected to standard conditions (68 F and 1 atm). H. All instruments used in collecting samples and monitoring operation shall be of the type and calibrated according to Table 1. [Basis: SMAQMD Rule 201, Section 303.2] 18. The initial source test shall consist of two sampling events: A. The first sampling event shall commence within the first 96 hours from start-up operation. If preliminary laboratory test results have not been received by the end of the 4 th calendar day from start-up, then the system shall be shut down. In addition, if the system cannot demonstrate compliance with the emission limits in Condition No. 7 or the VOC control efficiency requirement in Condition No. 9, then the system shall be shut down as soon as determining non-compliance. SMAQMD approval for start-up operation must be obtained for either of the aforementioned situations. B. The second sampling event shall be conducted seven operational days from the first sampling event. [Basis: SMAQMD Rule 201, Section 303.2] THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT NOTIFICATION & REPORTING 19. An initial source test report shall be submitted to the SMAQMD within 60 days following the completion of the initial source tests. The initial source test report shall use the SOIL VAPOR EXTRACTION INITIAL SOURCE TEST REPORT form (available at www.airquality.org), or shall include the following information: A. An as built process flow diagram, which includes all of the sampling and flow measurement locations. B. Lab analysis results of each pollutant of concern as specified in Condition No. 7 summarized in a table format, which shall include the date, time, hour meter readings, and all process parameters recorded every 15 minutes. Include lab analysis reports and the lab detection limits as an attachment. C. All calculations, including mass emission rate calculations, shall be in units of lbs/day for each pollutant of concern. D. For effluent samples that have pollutant concentrations below the lab detection limit, the lab detection limit must be used as the pollutant concentration when calculating the system emission rate. E. Any additional information that describes any modifications or revisions to the system design including adjustments of the preliminary process parameters (i.e., temperature, flow rates, etc.). F. Serial numbers from the summa canisters used to collect samples. 20. The SMAQMD shall be notified immediately after determining that the emission limits in Condition No. 7, the VOC control efficiency requirement in Condition No. 9, or the combustion temperature requirement in Condition No. 11 are found to be in non-compliance. Refer to SMAQMD Rule 602 Breakdown Conditions: Emergency Variance for applicable breakdown procedures to determine if breakdown conditions apply. 21. The attached SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT shall be submitted to the SMAQMD within 30 days following the end of each calendar year. 22. The permittee shall, upon determination of applicability and written notification by the SMAQMD, comply with all applicable requirements of the Air Toxics "Hot Spots" Information and Assessment Act (California Health and Safety Code Section 44300 et seq.). [Basis: SMAQMD Rule 201, Section 303.1] RECORDKEEPING 23. All sampling, analytical, and operational data shall be available for the most recent five-year period for inspection by the Air Pollution Control Officer upon request. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT TABLE 1 PARAMETERS AND ACCEPTABLE TEST EQUIPMENT Parameters Equipment Calibration* Temperature Pressure/Vacuum Gas Flow Fluid Flow Thermometer, Thermocouple, Temperature Controller Temperature Recorder Magnahelics, Std. Pressure Gauges Averaging Pitot Tube, Orifice Meter, Turbine Flow Meter, Hot Wire Anemometer Rotameter or other equivalent device Calibrated initially against a known NIST traceable standard. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a known NIST traceable standard (if applicable). Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a standard pressure barometer or pressure device that is NIST certified. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. * The manufacturer s certificate of calibration is acceptable if the date of certification, calibration accuracy, and length of time the certification is valid are included on the certificate. In addition, instruments purchased within 6 months of being used to take measurements, will be considered calibrated. However, dated purchase documentation must be provided. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT TABLE 2 SAMPLING AND ANALYTICAL METHODS Pollutant Sampling Methods Analytical Methods TPHg/VOC Benzene MtBE Trichloroethylene (TCE) Ethylene Dichloride (1,2-Dichloroethane) Tetrachloroethylene (Perchloroethylene, PCE) Chloroform Vinyl Chloride Methylene Chloride EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-3, EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B, CARB 410A/B EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT Your application for this air quality Authority to Construct was evaluated for compliance with Sacramento Metropolitan Air Quality Management District (SMAQMD), state and federal air quality rules. The following listed rules are those that are most applicable to the operation of your equipment. Other rules may also be applicable. SMAQMD RULE NO. RULE TITLE 201 GENERAL PERMIT REQUIREMENTS (8-24-06) 202 NEW SOURCE REVIEW (8-23-12) 217 PUBLIC NOTICE REQUIREMENTS FOR PERMITS (8-23-12) 401 RINGELMANN CHART (4-19-83) 402 NUISANCE (8-3-77) 404 PARTICULATE MATTER (11-20-84) 406 SPECIFIC CONTAMINANTS (12-6-78) 420 SULFUR CONTENT OF FUELS (8-13-81) 602 BREAKDOWN CONDITIONS: EMERGENCY VARIANCE (12-6-78) In addition, the conditions on this Authority to Construct may reflect some, but not all, requirements of these rules. There may be other conditions that are applicable to the operation of your equipment. Future changes in prohibitory rules may establish more stringent requirements which may supersede the conditions listed here. For further information please consult your SMAQMD rulebook or contact the SMAQMD for assistance. ATTACHMENTS: SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

Exhibit XIX-D Sample Authority to Construct Soil Vapor Extraction System Using Carbon Adsorption System Exhibit XIX-D

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT A/C NO.: 99998 & 99999 ISSUED BY: DATE ISSUED: MONTH DAY, YEAR PERMIT ENGINEER DATE EXPIRES: ISSUED TO: LOCATION: MONTH DAY, YEAR COMPANY NAME LOCATION ADDRESS, CITY, STATE ZIP PERMIT NO.: DESCRIPTION: 99998 SOIL VAPOR EXTRACTION SYSTEM: (specify number of soil vapor extraction wells only if source of contamination is other than typical gasoline or perchloroethylene: NUMBER OF VAPOR EXTRACTION WELLS: 5,) BLOWER: 5 HP, SVE MAXIMUM RATED CFM: 250. 99999 APCD: CARBON ADSORPTION SYSTEM VENTING A/C 99998, TWO CARBON UNITS CONNECTED IN SERIES, 2,000 POUND CAPACITY EACH UNIT, STACK HEIGHT: 10 FEET, STACK DIAMETER: 4 INCHES WITHOUT RAIN CAP. START-UP REQUIREMENTS AUTHORITY TO CONSTRUCT CONDITIONS S1. Upon installation of the equipment authorized in this Authority to Construct, the owner/operator shall contact the Sacramento Metropolitan Air Quality Management District (SMAQMD) at (916) 874-4800 to arrange for a start-up inspection. S2. This Authority to Construct shall serve as a temporary Permit to Operate provided that: A. The SMAQMD has been notified to conduct a start-up inspection. B. The equipment installed matches the equipment authorized in this Authority to Construct. C. The equipment is operated in compliance with all conditions listed within this Authority to Construct. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT GENERAL 1. The equipment shall be properly maintained and operated in accordance with the manufacturer s recommendations at all times. 2. The Air Pollution Control Officer and/or authorized representatives, upon the presentation of credentials shall be permitted: A. To enter upon the premises where the source is located or in which any records are required to be kept under the terms and conditions of this Authority to Construct, and B. At reasonable times to have access to and copy any records required to be kept under terms and conditions of this Authority to Construct, and C. To inspect any equipment, operation, or method required in this Authority to Construct, and D. To sample emissions from the source or require samples to be taken. 3. This Authority to Construct does not authorize the emission of air contaminants in excess of those allowed by Division 26, Part 4, Chapter 3, of the California Health and Safety Code or the Rules and Regulations of the SMAQMD. 4. The equipment shall not discharge such quantities of air contaminants or other materials which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. [Basis: SMAQMD Rule 402, Section 301] 5. A legible copy of this Authority to Construct shall be maintained on the premises with the equipment. [Basis: SMAQMD Rule 201, Section 401] EMISSION LIMITATIONS 6. The soil vapor extraction system and carbon adsorption system shall not discharge into the atmosphere any visible air contaminant other than uncombined water vapor for a period or periods aggregating more than three minutes in any one hour which is as dark or darker than Ringelmann No. 1 or equivalent to or greater than 20% opacity. [Basis: SMAQMD Rule 401, Section 301] 7. The emissions from the soil vapor extraction system and carbon adsorption system shall not emit: A. VOC in excess of 9.9 lb/day. B. PCE in excess of 0.049 lb/day. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT 8. The emissions from the soil vapor extraction system and carbon adsorption system shall not exceed the following limits: [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] Pollutant Emission Factors Maximum Allowable Emissions (A) lb/day lb/quarter lb/year VOC N/A (B) 911 3,614 PCE N/A (B) N/A N/A GHG 0 0 tons/day 0 tons/quarter 0 tons/year (A) The emission limit for VOC is based on the SMAQMD s VOC BACT limit. The PCE emission limit is based on a health risk assessment using EPA s ISCST model. Emissions based on hours/day, days/quarter, and 365 days/year of operation. GHG emission factor is expressed as CO2e and is from EPA s Mandatory Reporting of Greenhouse Gases Rule (74 FR 56260), Tables C-1 & C-2. (B) The daily emission limits for VOC and PCE are listed in Condition No. 7. 9. The carbon adsorption system shall attain the following VOC control efficiency corresponding to the influent VOC concentration as measured according to Condition No. 16 (unless the effluent VOC concentration is 10 ppmv or less as measured according to Condition No. 16): [Basis: SMAQMD Rule 202, Section 301] If VOC Concentration at Influent of Control Device (ppmv) is: Or if VOC Concentration at Effluent of Control Device (ppmv) is: Then Required VOC Control Efficiency is: (A) N/A <10 ppmv None >2,000 ppmv N/A >98.5% >200 ppmv to <2,000 ppmv N/A >97% <200 ppmv N/A >90% (A) VOC control efficiency calculated in accordance with the SOIL VAPOR EXTRACTION INITIAL SOURCE TEST REPORT form (available at www.airquality.org). EQUIPMENT OPERATION 10. All soil vapor extraction wells shall be capped to prevent vapors from venting into the atmosphere when not connected to the control device. In addition, all dilution air valves and soil vapor extraction wells shall be closed when the control device is not operating. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT 11. The soil vapor extraction system shall have a functioning meter to measure the hours of operation. The meter shall read at least 9,999 hours. 12. The soil vapor extraction system shall be vented to a carbon unit with at least two carbon canisters connected in series unless written authorization is obtained from the Air Pollution Control Officer. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] 13. The emission control device may be removed and vented directly to ambient air upon written approval from the Air Pollution Control Officer and under the following conditions: A. A modification application and applicable fees to request removal of the emission control device shall be submitted to the SMAQMD for approval 30 calendar days in advance. B. Daily total uncontrolled VOC emissions from the removal of the emission control device does not result in a daily emissions increase requiring BACT, calculated as the daily Potential to emit minus the daily Historic Potential Emissions. C. Total uncontrolled VOC emissions are less than 2 lbs/day and less than or equal to 10 ppm based on at least 3 months of continuous test data. D. The maximum excess cancer risk to any offsite receptor is less than or equal to 1 in a million and the maximum acute and chronic Hazard Index is less than 1 due to any uncontrolled emissions that have been identified as toxic air contaminants. 14. Carbon breakthrough shall be monitored by the use of a photo-ionization detector (PID), flame-ionization detector (FID), or other method approved in writing by the Air Pollution Control Officer. Monitoring shall be conducted on a monthly basis, unless a change to the monitoring schedule is proposed based on demonstrated breakthrough rates in the carbon vessels and approved in writing by the SMAQMD. A. The carbon breakthrough monitoring shall be performed at the following locations: 1) At the inlet to the second to last carbon vessel in series. 2) At the inlet to the last carbon vessel in series. 3) At the outlet of the last carbon vessel in series prior to venting to atmosphere. B. Breakthrough is defined as when the following occurs: 1) For the second to last carbon vessel, when the outlet of that carbon vessel is detected as the higher of the following: a) 10% of the inlet stream to the second to last carbon vessel, or b) 10 PPM or greater (measured as hexane). 2) For the last carbon vessel, when the outlet of that carbon vessel is detected as the higher of the following: a) 1.5% of the inlet stream to the second to last carbon vessel, or b) 10 PPM or greater (measured as hexane). C. Once breakthrough has been reached as defined above, the soil vapor extraction system shall be shut down immediately until: 1) Laboratory test results from tedlar bag or summa canister sampling demonstrate that carbon breakthrough has not been reached as defined above, or 2) The carbon is replaced as follows: THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT a) The carbon in the second to last carbon vessel shall be replaced with either fresh activated carbon or carbon from the last carbon vessel. b) The carbon in the last carbon vessel shall be replaced with fresh activated carbon. D. The results of all carbon breakthrough analysis shall be recorded on the attached SOIL VAPOR EXTRACTION CARBON BREAKTHROUGH MONITORING FORM. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] 15. All carbon and/or carbon canisters that have been disconnected from the soil vapor extraction system shall be stored in airtight containers while at or in transit from the remediation site. SOURCE TESTING REQUIREMENTS 16. Submittal of a source test plan 15 days prior to the initial source test is required for SMAQMD review and approval. This plan will be used for the initial source test and all subsequent tests to verify compliance with the emission limits in Condition No. 7 and the VOC control efficiency requirement in Condition No. 9. The source test shall be conducted in accordance with the following procedure: A. A sample from the influent and effluent of the emission control device shall be collected via summa canisters with a minimum 30-minute regulator. B. The SOIL VAPOR EXTRACTION FIELD DATA SHEET form (available at www.airquality.org) shall be completed for each source test, or the following information shall be recorded: 1) Applicable operational parameters listed in Table 1, recorded every 15 minutes or per an approved duration, 2) Hour meter readings for each sample event, 3) Date and time of samples taken, 4) Date and time of any measurements or readings taken, including PID/FID readings, and 5) Calibration date and calibration expiration date for PID/FID instruments and all other instruments used for gathering field data as listed in Table 1. C. Emission methods shall be those specified in Table 2 and shall be analyzed by a NELAP or ELAP certified laboratory. Other methods may be used providing the SMAQMD has approved the method in writing. D. Include the laboratory detection limits. All laboratory detection limits shall be in compliance with Condition No. 7. E. All sampling and flow measurement ports shall be located according to EPA or CARB Test Method 1 and shall include a detailed diagram of the sampling equipment. F. Specify the sampling tubing material type. All tubing used for sampling shall be made of material that will not absorb vapors from or emit contaminants into the sample, and the length shall not hold more than 5% of the sample container volume. G. Specify in detail how the standard volume flow rate (SCFM) will be measured and calculated for the stack effluent, corrected to standard conditions (68 F and 1 atm). H. All instruments used in collecting samples and monitoring operation shall be of the type and calibrated according to Table 1. I. Carbon breakthrough monitoring as specified in Condition No. 14. [Basis: SMAQMD Rule 201, Section 303.2] THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT 17. The initial source test shall consist of two sampling events: A. The first sampling event shall commence within the first 96 hours from start-up operation. If preliminary laboratory test results have not been received by the end of the 4 th calendar day from start-up, then the system shall be shut down. In addition, if the system cannot demonstrate compliance with the emission limits in Condition No. 7 or the VOC control efficiency requirement in Condition No. 9, then the system shall be shut down as soon as determining non-compliance. SMAQMD approval for start-up operation must be obtained for either of the aforementioned situations. B. The second sampling event shall be conducted seven operational days from the first sampling event. C. Each sampling event shall perform carbon breakthrough monitoring as specified in Condition No. 14. [Basis: SMAQMD Rule 201, Section 303.2] NOTIFICATION & REPORTING 18. An initial source test report shall be submitted to the SMAQMD within 60 days following the completion of the initial source tests. The initial source test report shall use the SOIL VAPOR EXTRACTION INITIAL SOURCE TEST REPORT form (available at www.airquality.org), or shall include the following information: A. An as built process flow diagram, which includes all of the sampling and flow measurement locations. B. Lab analysis results of each pollutant of concern as specified in Condition No. 7 summarized in a table format, which shall include the date, time, hour meter readings, and all process parameters recorded every 15 minutes. Include lab analysis reports and the lab detection limits as an attachment. C. All calculations, including mass emission rate calculations, shall be in units of lbs/day for each pollutant of concern. D. For effluent samples that have pollutant concentrations below the lab detection limit, the lab detection limit must be used as the pollutant concentration when calculating the system emission rate. E. Any additional information that describes any modifications or revisions to the system design including adjustments of the preliminary process parameters (i.e., temperature, flow rates, etc.). F. Serial numbers from the summa canisters used to collect samples. G. Results of all carbon breakthrough analysis as specified in Condition No. 14 and using the attached SOIL VAPOR EXTRACTION CARBON BREAKTHROUGH MONITORING FORM. 19. The SMAQMD shall be notified immediately after determining that the emission limits in Condition No. 7, the VOC control efficiency requirement in Condition No. 9, or the carbon breakthrough monitoring limits of Condition No. 14 are found to be in non-compliance. Refer to SMAQMD Rule 602 Breakdown Conditions: Emergency Variance for applicable breakdown procedures to determine if breakdown conditions apply. 20. The attached SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT shall be submitted to the SMAQMD within 30 days following the end of each calendar year. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT 21. The permittee shall, upon determination of applicability and written notification by the SMAQMD, comply with all applicable requirements of the Air Toxics "Hot Spots" Information and Assessment Act (California Health and Safety Code Section 44300 et seq.). [Basis: SMAQMD Rule 201, Section 303.1] RECORDKEEPING 22. All sampling, analytical, and operational data shall be available for the most recent five-year period for inspection by the Air Pollution Control Officer upon request. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT TABLE 1 PARAMETERS AND ACCEPTABLE TEST EQUIPMENT Parameters Equipment Calibration* Temperature Pressure/Vacuum Gas Flow Fluid Flow Thermometer, Thermocouple, Temperature Controller Temperature Recorder Magnahelics, Std. Pressure Gauges Averaging Pitot Tube, Orifice Meter, Turbine Flow Meter, Hot Wire Anemometer Rotameter or other equivalent device Calibrated initially against a known NIST traceable standard. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a caseby-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a known NIST traceable standard (if applicable). Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a standard pressure barometer or pressure device that is NIST certified. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. * The manufacturer s certificate of calibration is acceptable if the date of certification, calibration accuracy, and length of time the certification is valid are included on the certificate. In addition, instruments purchased within 6 months of being used to take measurements, will be considered calibrated. However, dated purchase documentation must be provided. THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT TABLE 2 SAMPLING AND ANALYTICAL METHODS Pollutant Sampling Methods Analytical Methods TPHg/VOC Benzene MtBE Trichloroethylene (TCE) Ethylene Dichloride (1,2-Dichloroethane) Tetrachloroethylene (Perchloroethylene, PCE) Chloroform Vinyl Chloride Methylene Chloride EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-3, EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B, CARB 410A/B EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

777 12TH STREET, 3RD FLOOR SACRAMENTO METROPOLITAN SACRAMENTO, CA 95814-1908 AIR QUALITY MANAGEMENT DISTRICT AUTHORITY TO CONSTRUCT Your application for this air quality Authority to Construct was evaluated for compliance with Sacramento Metropolitan Air Quality Management District (SMAQMD), state and federal air quality rules. The following listed rules are those that are most applicable to the operation of your equipment. Other rules may also be applicable. SMAQMD RULE NO. RULE TITLE 201 GENERAL PERMIT REQUIREMENTS (8-24-06) 202 NEW SOURCE REVIEW (8-23-12) 217 PUBLIC NOTICE REQUIREMENTS FOR PERMITS (8-23-12) 401 RINGELMANN CHART (4-19-83) 402 NUISANCE (8-3-77) 602 BREAKDOWN CONDITIONS: EMERGENCY VARIANCE (12-6-78) In addition, the conditions on this Authority to Construct may reflect some, but not all, requirements of these rules. There may be other conditions that are applicable to the operation of your equipment. Future changes in prohibitory rules may establish more stringent requirements which may supersede the conditions listed here. For further information please consult your SMAQMD rulebook or contact the SMAQMD for assistance. ATTACHMENTS: SOIL VAPOR EXTRACTION CARBON BREAKTHROUGH MONITORING FORM SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT THIS IS NOT A PERMIT TO OPERATE A/C NOS.: 99998 & 99998

Exhibit XIX-E Sample Permit to Operate Soil Vapor Extraction System Using Natural Gas Fired Thermal/Catalytic Oxidizer Exhibit XIX-E

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 PERMIT TO OPERATE ISSUED TO: COMPANY NAME EQUIPMENT LOCATION: LOCATION ADDRESS, CITY, STATE, ZIP PERMIT NO. GENERAL EQUIPMENT DESCRIPTION 99998 SOIL VAPOR EXTRACTION SYSTEM: (specify number of soil vapor extraction wells only if source of contamination is other than typical gasoline or perchloroethylene: NUMBER OF VAPOR EXTRACTION WELLS: 5,) BLOWER RATING: 7.5 HP, SVE MAXIMUM RATED FLOW RATE: 350 SCFM, DILUTION BLOWER MAXIMUM RATED FLOW RATE: 75 SCFM, TOTAL SYSTEM MAXIMUM RATED FLOW RATE: 425 SCFM. 99999 APCD: THERMAL OXIDIZER, THERMAL/CATALYTIC OXIDIZER OR ELECTRIC CATALYTIC OXIDIZER FOR P/O 99998, MAKE: SOLLECO, MODEL: TCAT350, RATED HEAT INPUT: 0.4 MMBTU/HR, NATURAL GAS FIRED, STACK HEIGHT: 16 FEET, STACK DIAMETER: 20 INCHES WITHOUT RAIN CAP. SUBJECT TO THE FOLLOWING CONDITIONS: 1. The equipment shall be properly maintained and operated in accordance with the manufacturer s recommendations at all times. 2. The Air Pollution Control Officer and/or authorized representatives, upon the presentation of credentials shall be permitted: A. To enter upon the premises where the source is located or in which any records are required to be kept under the terms and conditions of this Permit to Operate, and B. At reasonable times to have access to and copy any records required to be kept under terms and conditions of this Permit to Operate, and C. To inspect any equipment, operation, or method required in this Permit to Operate, and D. To sample emissions from the source or require samples to be taken. LARRY GREENE DATE ISSUED: MM-DD-YYYY AIR POLLUTION CONTROL OFFICER DATE EXPIRES: MM-DD-YYYY (UNLESS RENEWED) BY: REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT 3. This Permit to Operate does not authorize the emission of air contaminants in excess of those allowed by Division 26, Part 4, Chapter 3, of the California Health and Safety Code or the Rules and Regulations of the Sacramento Metropolitan Air Quality Management District (SMAQMD). 4. The equipment shall not discharge such quantities of air contaminants or other materials which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. [Basis: SMAQMD Rule 402, Section 301] 5. A legible copy of this Permit to Operate shall be maintained on the premises with the equipment. [Basis: SMAQMD Rule 201, Section 401] EMISSIONS LIMITATIONS 6. The soil vapor extraction system and thermal/catalytic oxidizer shall not discharge into the atmosphere any visible air contaminant other than uncombined water vapor for a period or periods aggregating more than three minutes in any one hour which is as dark or darker than Ringelmann No. 1 or equivalent to or greater than 20% opacity. [Basis: SMAQMD Rule 401, Section 301] 7. The emissions from the soil vapor extraction system and thermal/catalytic oxidizer shall not emit: A. VOC in excess of 9.9 lb/day. B. Benzene in excess of 0.019 lb/day. C. MtBE in excess of 0.136 lb/day. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] 8. The emissions from the soil vapor extraction system and thermal/catalytic oxidizer shall not exceed the following limits: [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] Pollutant Emission Factors (A) (lb/mmcf) Maximum Allowable Emissions (B) lb/day lb/quarter lb/year VOC N/A (C) 911 3,614 NOx 100 1.0 88 350 SOx 0.6 0.01 1 2 PM10 7.6 0.1 7 27 PM2.5 7.6 0.1 7 27 CO 84 0.8 74 294 Benzene N/A (C) N/A N/A MtBE N/A (C) N/A N/A GHG 117,000 0.6 tons/day 52 tons/quarter 205 tons/year REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT (A) Emission factors for NOx, SOx, PM10, and CO are from AP-42, Table 1.4-1 and 1.4-2 (7/98) for natural gas combustion. Emission factor for PM2.5 is the PM10 factor assuming all PM10 to be PM2.5. GHG emission factor is expressed as CO2e and is from EPA s Mandatory Reporting of Greenhouse Gases Rule (74 FR 56260), Tables C-1 & C-2. (B) The emission limit for VOC is based on the SMAQMD s VOC BACT limit. NOx, SOx, PM10, and CO emissions are based on the maximum rated capacity of 400 cf/hour, 24 hours/day, 92 days/quarter, and 365 days/year of operation, and the emission factors listed in this table. The benzene and MtBE emission limits are based on a health risk assessment using EPA s ISCST model. (C) The daily emission limits for VOC, benzene, and MtBE are listed in Condition No. 7. 9. The thermal/catalytic oxidizer shall attain the following VOC control efficiency corresponding to the influent VOC concentration as measured according to Condition No. 17 (unless the effluent VOC concentration is 10 ppmv or less as measured according to Condition No. 17): [Basis: SMAQMD Rule 202, Section 301] If VOC Concentration at Influent of Control Device (ppmv) is: Or if VOC Concentration at Effluent of Control Device (ppmv) is: Then Required VOC Control Efficiency is: (A) N/A <10 ppmv None >2,000 ppmv N/A >98.5% >200 ppmv to <2,000 ppmv N/A >97% <200 ppmv N/A >90% (A) VOC control efficiency calculated in accordance with the SOIL VAPOR EXTRACTION SOURCE TEST REPORT form (available at www.airquality.org). EQUIPMENT OPERATION 10. The thermal/catalytic oxidizer shall only be fueled by pipeline-quality natural gas. 11. The thermal/catalytic oxidizer will be operated at a combustion temperature of 600 F or higher while the soil vapor extraction system is operating in catalytic oxidizer mode and 1400 F or higher while the soil vapor extraction system is operating in thermal oxidizer mode. In addition, the thermal/catalytic oxidizer shall be equipped with a continuous combustion temperature recorder. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] 12. All soil vapor extraction wells shall be capped to prevent vapors from venting into the atmosphere when not connected to the control device. In addition, all dilution air valves and soil vapor extraction wells shall be closed when the control device is not operating. 13. The soil vapor extraction system shall have a functioning meter to measure the hours of operation. The meter shall read at least 9,999 hours. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT 14. The soil vapor extraction system shall be vented to a thermal/catalytic oxidizer during all operational periods. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] 15. The emission control device may be removed and vented directly to ambient air upon written approval from the Air Pollution Control Officer and under the following conditions: A. A modification application and applicable fees to request removal of the emission control device shall be submitted to the SMAQMD for approval 30 calendar days in advance. B. Daily total uncontrolled VOC emissions from the removal of the emission control device does not result in a daily emissions increase requiring BACT, calculated as the daily Potential to emit minus the daily Historic Potential Emissions. C. Total uncontrolled VOC emissions are less than 2 lbs/day and less than or equal to 10 ppm based on at least 3 months of continuous test data. D. The maximum excess cancer risk to any offsite receptor is less than or equal to 1 in a million and the maximum acute and chronic Hazard Index is less than 1 due to any uncontrolled emissions that have been identified as toxic air contaminants. 16. The soil vapor extraction system will not be used to treat any halogenated compounds or chlorinated compounds or toxic compounds except benzene, MtBE, ethyl benzene, toluene, and xylenes. A. If any halogenated compounds or chlorinated compounds or other toxic compounds are detected, then within 15 days of the date of the lab analysis report: 1) A summa canister sample of the influent of the system shall be collected and analyzed in accordance with the procedure as the previous sample and the lab analysis results submitted to the SMAQMD, and 2) The system shall be shut down. B. If the system continues to show detection of halogenated compounds or chlorinated compounds, the system shall remain shut down and the owner/operator shall: 1) Within 30 days of the date of the 2 nd lab analysis report, conduct a source test of the effluent of the system for polychlorinated dibenzo-p-dioxins and polychlorinated dibenzofurans (PCDDs and PCDFs), or 2) Within 30 days of the lab analysis report, apply for an Authority to Construct/Permit to Operate a carbon adsorption system to replace or follow the thermal/catalytic oxidizer. C. If the system continues to show detection of other toxic compounds, the system shall remain shut down and be subject to reevaluation. A modification application and applicable fees may apply. D. SMAQMD approval must be obtained prior to restarting the system for operation. SOURCE TESTING REQUIREMENTS 17. The soil vapor extraction system and thermal/catalytic oxidizer shall be tested by the end of each calendar year to verify compliance with the emission limits in Condition No. 7 and the VOC control efficiency requirement in Condition No. 9. The source test shall be conducted in accordance with the original approved source test plan and the following procedure: A. A sample from the influent and effluent of the emission control device shall be collected via summa canisters with a minimum 30-minute regulator. B. The SOIL VAPOR EXTRACTION FIELD DATA SHEET form (available at www.airquality.org) shall be completed for each source test, or the following information shall be recorded: REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT 1) Applicable operational parameters listed in Table 1, recorded every 15 minutes or per an approved duration, 2) Hour meter readings for each sample event, 3) Date and time of samples taken, 4) Date and time of any measurements or readings taken, including PID/FID readings, and 5) Calibration date and calibration expiration date for PID/FID instruments and all other instruments used for gathering field data as listed in Table 1. C. Emission methods shall be those specified in Table 2 and shall be analyzed by a NELAP or ELAP certified laboratory. Other methods may be used providing the SMAQMD has approved the method in writing. D. Include the laboratory detection limits. All laboratory detection limits shall be in compliance with Condition No. 7. E. All sampling and flow measurement ports shall be located according to EPA or CARB Test Method 1 and shall include a detailed diagram of the sampling equipment. F. Specify the sampling tubing material type. All tubing used for sampling shall be made of material that will not absorb vapors from or emit contaminants into the sample, and the length shall not hold more than 5% of the sample container volume. G. Specify in detail how the standard volume flow rate (SCFM) will be measured and calculated for the stack effluent, corrected to standard conditions (68 F and 1 atm). H. All instruments used in collecting samples and monitoring operation shall be of the type and calibrated according to Table 1. [Basis: SMAQMD Rule 201, Section 303.2] NOTIFICATION & REPORTING 18. At least 30 days prior to the source test, the permittee shall notify the Air Pollution Control Officer of the exact date and time of the test. 19. Source test reports shall be submitted to the SMAQMD within 60 days following the completion of the source test. The source test report shall use the SOIL VAPOR EXTRACTION SOURCE TEST REPORT form (available at www.airquality.org), or shall include the following information: A. An as built process flow diagram, which includes all of the sampling and flow measurement locations. B. Lab analysis results of each pollutant of concern as specified in Condition No. 7 summarized in a table format, which shall include the date, time, hour meter readings, and all process parameters recorded every 15 minutes. Include lab analysis reports and the lab detection limits as an attachment. C. All calculations, including mass emission rate calculations, shall be in units of lbs/day for each pollutant of concern. D. For effluent samples that have pollutant concentrations below the lab detection limit, the lab detection limit must be used as the pollutant concentration when calculating the system emission rate. E. Any additional information that describes any modifications or revisions to the system design including adjustments of the preliminary process parameters (i.e., temperature, flow rates, etc.). F. Serial numbers from the summa canisters used to collect samples. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT 20. The SMAQMD shall be notified immediately after determining that the emission limits in Condition No. 7, the VOC control efficiency requirement in Condition No. 9, or the combustion temperature requirement in Condition No. 11 are found to be in non-compliance. Refer to SMAQMD Rule 602 Breakdown Conditions: Emergency Variance for applicable breakdown procedures to determine if breakdown conditions apply. 21. The attached SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT shall be submitted to the SMAQMD within 30 days following the end of each calendar year. 22. The permittee shall, upon determination of applicability and written notification by the SMAQMD, comply with all applicable requirements of the Air Toxics "Hot Spots" Information and Assessment Act (California Health and Safety Code Section 44300 et seq.). [Basis: SMAQMD Rule 201, Section 303.1] RECORDKEEPING 23. All sampling, analytical, and operational data shall be available for the most recent five-year period for inspection by the Air Pollution Control Officer upon request. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT TABLE 1 PARAMETERS AND ACCEPTABLE TEST EQUIPMENT Parameters Equipment Calibration* Temperature Pressure/Vacuum Gas Flow Fluid Flow Thermometer, Thermocouple, Temperature Controller Temperature Recorder Magnahelics, Std. Pressure Gauges Averaging Pitot Tube, Orifice Meter, Turbine Flow Meter, Hot Wire Anemometer Rotameter or other equivalent device Calibrated initially against a known NIST traceable standard. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a caseby-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a known NIST traceable standard (if applicable). Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a standard pressure barometer or pressure device that is NIST certified. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. * The manufacturer s certificate of calibration is acceptable if the date of certification, calibration accuracy, and length of time the certification is valid are included on the certificate. In addition, instruments purchased within 6 months of being used to take measurements, will be considered calibrated. However, dated purchase documentation must be provided. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT TABLE 2 SAMPLING AND ANALYTICAL METHODS Pollutant Sampling Methods Analytical Methods TPHg/VOC Benzene MtBE Trichloroethylene (TCE) Ethylene Dichloride (1,2-Dichloroethane) Tetrachloroethylene (Perchloroethylene, PCE) Chloroform Vinyl Chloride Methylene Chloride EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-3, EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B, CARB 410A/B EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT Your application for this air quality Permit to Operate was evaluated for compliance with Sacramento Metropolitan Air Quality Management District (SMAQMD), state and federal air quality rules. The following listed rules are those that are most applicable to the operation of your equipment. Other rules may also be applicable. SMAQMD RULE NO. RULE TITLE 201 GENERAL PERMIT REQUIREMENTS (8-24-06) 202 NEW SOURCE REVIEW (8-23-12) 217 PUBLIC NOTICE REQUIREMENTS FOR PERMITS (8-23-12) 401 RINGELMANN CHART (4-19-83) 402 NUISANCE (8-3-77) 404 PARTICULATE MATTER (11-20-84) 406 SPECIFIC CONTAMINANTS (12-6-78) 420 SULFUR CONTENT OF FUELS (8-13-81) 602 BREAKDOWN CONDITIONS: EMERGENCY VARIANCE (12-6-78) In addition, the conditions on this Permit to Operate may reflect some, but not all, requirements of these rules. There may be other conditions that are applicable to the operation of your equipment. Future changes in prohibitory rules may establish more stringent requirements which may supersede the conditions listed here. For further information please consult your SMAQMD rulebook or contact the SMAQMD for assistance. ATTACHMENTS: SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

Exhibit XIX-F Sample Permit to Operate Soil Vapor Extraction System Using Carbon Adsorption System Exhibit XIX-F

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 PERMIT TO OPERATE ISSUED TO: COMPANY NAME EQUIPMENT LOCATION: LOCATION ADDRESS, CITY, STATE, ZIP PERMIT NO. GENERAL EQUIPMENT DESCRIPTION 99998 SOIL VAPOR EXTRACTION SYSTEM: (specify number of soil vapor extraction wells only if source of contamination is other than typical gasoline or perchloroethylene: NUMBER OF VAPOR EXTRACTION WELLS: 5,) BLOWER: 5 HP, SVE MAXIMUM RATED CFM: 250. 99999 APCD: CARBON ADSORPTION SYSTEM VENTING P/O 99998, TWO CARBON UNITS CONNECTED IN SERIES, 2,000 POUND CAPACITY EACH UNIT, STACK HEIGHT: 10 FEET, STACK DIAMETER: 4 INCHES WITHOUT RAIN CAP. SUBJECT TO THE FOLLOWING CONDITIONS: 1. The equipment shall be properly maintained and operated in accordance with the manufacturer s recommendations at all times. 2. The Air Pollution Control Officer and/or authorized representatives, upon the presentation of credentials shall be permitted: A. To enter upon the premises where the source is located or in which any records are required to be kept under the terms and conditions of this Permit to Operate, and B. At reasonable times to have access to and copy any records required to be kept under terms and conditions of this Permit to Operate, and C. To inspect any equipment, operation, or method required in this Permit to Operate, and D. To sample emissions from the source or require samples to be taken. LARRY GREENE DATE ISSUED: MM-DD-YYYY AIR POLLUTION CONTROL OFFICER DATE EXPIRES: MM-DD-YYYY (UNLESS RENEWED) BY: REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT 3. This Permit to Operate does not authorize the emission of air contaminants in excess of those allowed by Division 26, Part 4, Chapter 3, of the California Health and Safety Code or the Rules and Regulations of the Sacramento Metropolitan Air Quality Management District (SMAQMD). 4. The equipment shall not discharge such quantities of air contaminants or other materials which cause injury, detriment, nuisance or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. [Basis: SMAQMD Rule 402, Section 301] 5. A legible copy of this Permit to Operate shall be maintained on the premises with the equipment. [Basis: SMAQMD Rule 201, Section 401] EMISSIONS LIMITATIONS 6. The soil vapor extraction system and carbon adsorption system shall not discharge into the atmosphere any visible air contaminant other than uncombined water vapor for a period or periods aggregating more than three minutes in any one hour which is as dark or darker than Ringelmann No. 1 or equivalent to or greater than 20% opacity. [Basis: SMAQMD Rule 401, Section 301] 7. The emissions from the soil vapor extraction system and carbon adsorption system shall not emit: A. VOC in excess of 9.9 lb/day. B. PCE in excess of 0.049 lb/day. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] 8. The emissions from the soil vapor extraction system and carbon adsorption system shall not exceed the following limits: [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] Pollutant Emission Factors Maximum Allowable Emissions (A) lb/day lb/quarter lb/year VOC N/A (B) 911 3,614 PCE N/A (B) N/A N/A GHG 0 0 tons/day 0 tons/quarter 0 tons/year (A) The emission limit for VOC is based on the SMAQMD s VOC BACT limit. The PCE emission limit is based on a health risk assessment using EPA s ISCST model. Emissions based on hours/day, days/quarter, and 365 days/year of operation. GHG emission factor is expressed as CO2e and is from EPA s Mandatory Reporting of Greenhouse Gases Rule (74 FR 56260), Tables C-1 & C-2. (B) The daily emission limits for VOC and PCE are listed in Condition No. 7. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT 9. The carbon adsorption system shall attain the following VOC control efficiency corresponding to the influent VOC concentration as measured according to Condition No. 16 (unless the effluent VOC concentration is 10 ppmv or less as measured according to Condition No. 16): [Basis: SMAQMD Rule 202, Section 301] If VOC Concentration at Influent of Control Device (ppmv) is: Or if VOC Concentration at Effluent of Control Device (ppmv) is: Then Required VOC Control Efficiency is: (A) N/A <10 ppmv None >2,000 ppmv N/A >98.5% >200 ppmv to <2,000 ppmv N/A >97% <200 ppmv N/A >90% (A) VOC control efficiency calculated in accordance with the SOIL VAPOR EXTRACTION SOURCE TEST REPORT form (available at www.airquality.org). EQUIPMENT OPERATION 10. All soil vapor extraction wells shall be capped to prevent vapors from venting into the atmosphere when not connected to the control device. In addition, all dilution air valves and soil vapor extraction wells shall be closed when the control device is not operating. 11. The soil vapor extraction system shall have a functioning meter to measure the hours of operation. The meter shall read at least 9,999 hours. 12. The soil vapor extraction system shall be vented to a carbon unit with at least two carbon canisters connected in series unless written authorization is obtained from the Air Pollution Control Officer. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] 13. The emission control device may be removed and vented directly to ambient air upon written approval from the Air Pollution Control Officer and under the following conditions: A. A modification application and applicable fees to request removal of the emission control device shall be submitted to the SMAQMD for approval 30 calendar days in advance. B. Daily total uncontrolled VOC emissions from the removal of the emission control device does not result in a daily emissions increase requiring BACT, calculated as the daily Potential to emit minus the daily Historic Potential Emissions. C. Total uncontrolled VOC emissions are less than 2 lbs/day and less than or equal to 10 ppm based on at least 3 months of continuous test data. D. The maximum excess cancer risk to any offsite receptor is less than or equal to 1 in a million and the maximum acute and chronic Hazard Index is less than 1 due to any uncontrolled emissions that have been identified as toxic air contaminants. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT 14. Carbon breakthrough shall be monitored by the use of a photo-ionization detector (PID), flame-ionization detector (FID), or other method approved in writing by the Air Pollution Control Officer. Monitoring shall be conducted on a monthly basis, unless a change to the monitoring schedule is proposed based on demonstrated breakthrough rates in the carbon vessels and approved in writing by the SMAQMD. A. The carbon breakthrough monitoring shall be performed at the following locations: 1) At the inlet to the second to last carbon vessel in series. 2) At the inlet to the last carbon vessel in series. 3) At the outlet of the last carbon vessel in series prior to venting to atmosphere. B. Breakthrough is defined as when the following occurs: 1) For the second to last carbon vessel, when the outlet of that carbon vessel is detected as the higher of the following: a) 10% of the inlet stream to the second to last carbon vessel, or b) 10 PPM or greater (measured as hexane). 2) For the last carbon vessel, when the outlet of that carbon vessel is detected as the higher of the following: a) 1.5% of the inlet stream to the second to last carbon vessel, or b) 10 PPM or greater (measured as hexane). C. Once breakthrough has been reached as defined above, the soil vapor extraction system shall be shut down immediately until: 1) Laboratory test results from tedlar bag or summa canister sampling demonstrate that carbon breakthrough has not been reached as defined above, or 2) The carbon is replaced as follows: a) The carbon in the second to last carbon vessel shall be replaced with either fresh activated carbon or carbon from the last carbon vessel. b) The carbon in the last carbon vessel shall be replaced with fresh activated carbon. D. The results of all carbon breakthrough analysis shall be recorded on the attached SOIL VAPOR EXTRACTION CARBON BREAKTHROUGH MONITORING FORM. [Basis: SMAQMD Rule 201, Section 405 and Rule 202, Section 301] 15. All carbon and/or carbon canisters that have been disconnected from the soil vapor extraction system shall be stored in airtight containers while at or in transit from the remediation site. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SOURCE TESTING REQUIREMENTS SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT 16. The soil vapor extraction system and carbon adsorption system shall be tested by the end of each calendar year to verify compliance with the emission limits in Condition No. 7 and the VOC control efficiency requirement in Condition No. 9. The source test shall be conducted in accordance with the original approved source test plan and the following procedure: A. A sample from the influent and effluent of the emission control device shall be collected via summa canisters with a minimum 30-minute regulator. B. The SOIL VAPOR EXTRACTION FIELD DATA SHEET form (available at www.airquality.org) shall be completed for each source test, or the following information shall be recorded: 1) Applicable operational parameters listed in Table 1, recorded every 15 minutes or per an approved duration, 2) Hour meter readings for each sample event, 3) Date and time of samples taken, 4) Date and time of any measurements or readings taken, including PID/FID readings, and 5) Calibration date and calibration expiration date for PID/FID instruments and all other instruments used for gathering field data as listed in Table 1. C. Emission methods shall be those specified in Table 2 and shall be analyzed by a NELAP or ELAP certified laboratory. Other methods may be used providing the SMAQMD has approved the method in writing. D. Include the laboratory detection limits. All laboratory detection limits shall be in compliance with Condition No. 7. E. All sampling and flow measurement ports shall be located according to EPA or CARB Test Method 1 and shall include a detailed diagram of the sampling equipment. F. Specify the sampling tubing material type. All tubing used for sampling shall be made of material that will not absorb vapors from or emit contaminants into the sample, and the length shall not hold more than 5% of the sample container volume. G. Specify in detail how the standard volume flow rate (SCFM) will be measured and calculated for the stack effluent, corrected to standard conditions (68 F and 1 atm). H. All instruments used in collecting samples and monitoring operation shall be of the type and calibrated according to Table 1. I. Carbon breakthrough monitoring as specified in Condition No. 14. [Basis: SMAQMD Rule 201, Section 303.2] NOTIFICATION & REPORTING 17. At least 30 days prior to the source test, the permittee shall notify the Air Pollution Control Officer of the exact date and time of the test. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT 18. Source test reports shall be submitted to the SMAQMD within 60 days following the completion of the source test. The source test report shall use the SOIL VAPOR EXTRACTION SOURCE TEST REPORT form (available at www.airquality.org), or shall include the following information: A. An as built process flow diagram, which includes all of the sampling and flow measurement locations. B. Lab analysis results of each pollutant of concern as specified in Condition No. 7 summarized in a table format, which shall include the date, time, hour meter readings, and all process parameters recorded every 15 minutes. Include lab analysis reports and the lab detection limits as an attachment. C. All calculations, including mass emission rate calculations, shall be in units of lbs/day for each pollutant of concern. D. For effluent samples that have pollutant concentrations below the lab detection limit, the lab detection limit must be used as the pollutant concentration when calculating the system emission rate. E. Any additional information that describes any modifications or revisions to the system design including adjustments of the preliminary process parameters (i.e., temperature, flow rates, etc.). F. Serial numbers from the summa canisters used to collect samples. G. Results of all carbon breakthrough analysis as specified in Condition No. 14 and using the attached SOIL VAPOR EXTRACTION CARBON BREAKTHROUGH MONITORING FORM. 19. The SMAQMD shall be notified immediately after determining that the emission limits in Condition No. 7, the VOC control efficiency requirement in Condition No. 9, or the carbon breakthrough monitoring limits of Condition No. 14 are found to be in non-compliance. Refer to SMAQMD Rule 602 Breakdown Conditions: Emergency Variance for applicable breakdown procedures to determine if breakdown conditions apply. 20. The attached SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT shall be submitted to the SMAQMD within 30 days following the end of each calendar year. 21. The permittee shall, upon determination of applicability and written notification by the SMAQMD, comply with all applicable requirements of the Air Toxics "Hot Spots" Information and Assessment Act (California Health and Safety Code Section 44300 et seq.). [Basis: SMAQMD Rule 201, Section 303.1] RECORDKEEPING 22. All sampling, analytical, and operational data shall be available for the most recent five-year period for inspection by the Air Pollution Control Officer upon request. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT TABLE 1 PARAMETERS AND ACCEPTABLE TEST EQUIPMENT Parameters Equipment Calibration* Temperature Pressure/Vacuum Gas Flow Fluid Flow Thermometer, Thermocouple, Temperature Controller Temperature Recorder Magnahelics, Std. Pressure Gauges Averaging Pitot Tube, Orifice Meter, Turbine Flow Meter, Hot Wire Anemometer Rotameter or other equivalent device Calibrated initially against a known NIST traceable standard. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a caseby-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a known NIST traceable standard (if applicable). Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated initially against a standard pressure barometer or pressure device that is NIST certified. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. Calibrated annually, as recommended by the manufacturer if more frequent, or upon a frequency as approved by the SMAQMD on a case-by-case basis. For all sampling events, proof of calibration must be available on site for inspector review and approval. * The manufacturer s certificate of calibration is acceptable if the date of certification, calibration accuracy, and length of time the certification is valid are included on the certificate. In addition, instruments purchased within 6 months of being used to take measurements, will be considered calibrated. However, dated purchase documentation must be provided. REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT TABLE 2 SAMPLING AND ANALYTICAL METHODS Pollutant Sampling Methods Analytical Methods TPHg/VOC Benzene MtBE Trichloroethylene (TCE) Ethylene Dichloride (1,2-Dichloroethane) Tetrachloroethylene (Perchloroethylene, PCE) Chloroform Vinyl Chloride Methylene Chloride EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-15 (Summa Canister) OR CARB 410 A/B (Tedlar Bag) EPA TO-3, EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B, CARB 410A/B EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15, EPA 8260B EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 EPA TO-14A, EPA TO-15 REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999

777 12 TH ST., 3 RD FLOOR (916) 874-4800 SACRAMENTO, CA 95814-1908 FAX (916) 874-4899 SACRAMENTO METROPOLITAN AIR QUALITY MANAGEMENT DISTRICT Your application for this air quality Permit to Operate was evaluated for compliance with Sacramento Metropolitan Air Quality Management District (SMAQMD), state and federal air quality rules. The following listed rules are those that are most applicable to the operation of your equipment. Other rules may also be applicable. SMAQMD RULE NO. RULE TITLE 201 GENERAL PERMIT REQUIREMENTS (8-24-06) 202 NEW SOURCE REVIEW (8-23-12) 217 PUBLIC NOTICE REQUIREMENTS FOR PERMITS (8-23-12) 401 RINGELMANN CHART (4-19-83) 402 NUISANCE (8-3-77) 602 BREAKDOWN CONDITIONS: EMERGENCY VARIANCE (12-6-78) In addition, the conditions on this Permit to Operate may reflect some, but not all, requirements of these rules. There may be other conditions that are applicable to the operation of your equipment. Future changes in prohibitory rules may establish more stringent requirements which may supersede the conditions listed here. For further information please consult your SMAQMD rulebook or contact the SMAQMD for assistance. ATTACHMENTS: SOIL VAPOR EXTRACTION CARBON BREAKTHROUGH MONITORING FORM SOIL VAPOR EXTRACTION ANNUAL CERTIFICATION REPORT REVOCABLE AND NON-TRANSFERABLE PERMIT NOS.: 99998 & 99999