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Frontier Transportation, Inc.• • <br /> 425 Larch Road <br /> Page 3 of 3 <br /> of a sheen during one quarter of monitoring does not suggest a significant problem to <br /> EHD with conducting a pumping test in the former tank pit area, especially if the source <br /> of the sheen is impacted soil in the shallow saturated zone as speculated by BEAI. This <br /> issue requires further examination before EHD can concur with the proposed test design. <br /> • The EHD requires additional information on the free product sheen before approving or <br /> disapproving the proposed installation of passive free product skimmers in monitoring <br /> wells MW-2 and MW-21. Persistence of the sheen and a technically justifiable estimate <br /> of the recoverable free product volume should be provided to evaluate this <br /> recommendation. <br /> As the comments above indicate, BEAI has provided insufficient technical detail and <br /> justification for their proposed corrective action plans. The Interim Corrective Action Plan and <br /> the current AICAP have both failed to obtain EHD approval for much the same reason, and now <br /> a third must be submitted before the corrective action on your site can progress. Overdue and/or <br /> inadequate reports and work plans retard progress toward closure for your site. For your <br /> information, EHD has been informed that the State Cleanup Fund reimbursement program is <br /> scheduled to sunset in December 2010 and there are no current plans to seek a reauthorization for <br /> the program. To date, no remediation of impacted groundwater has occurred and impacted soil <br /> that is potentially still impacting groundwater remains on your site. Once cleanup has been <br /> initiated it may still take a number of years to adequately clean the site and groundwater and to <br /> perform confirmation monitoring and sampling. With the possibility that the Cleanup Fund will <br /> not be extended beyond the currently remaining 4 years of the program life, you are encouraged <br /> to make optimum use of the current reimbursement program and move your site toward closure <br /> as rapidly as is technically possible. <br /> By this letter, the EHD directs you to: <br /> • Submit all future quarterly reports within 60 days of conducting the quarterly <br /> groundwater monitoring event; <br /> • Submit to EHD no later than 14 August 2006 a corrective action plan addendum or <br /> revision that adequately addresses the concerns EHD expressed by letter dated 02 March <br /> 2006 and this letter regarding the ICAP and AICAP. <br /> Please contact Vicki McCartney, REHS, at(209) 468-3456 or vmccartney0a sicehd.com, if you <br /> have any questions regarding this letter. <br /> Donna Heran, REHS, Director <br /> V�ictoria <br /> Environm�enta�l Health Department�� �L. McCartney, Senior REHS Nuel C. Henderson, Jr., PG <br /> LOP/Site Mitigation Unit N Engineering Geologist, Unit IV <br /> C: David Blakely, BEAI <br /> James L.L. Barton, CVRWQCB <br />