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Frontier Transportation, Inc. <br /> 425 Larch Road <br /> Page 2 of 2 <br /> adsorbed and absorbed (sorbed) and questions the presence of floating free product and <br /> the risk assessment presented in this action plan. Therefore, at the current time EHD <br /> does not see the urgency to take immediate action;however,if you have additional <br /> information that demonstrates a need for immediate action,please supply the information <br /> to EHD for a prompt reconsideration of the proposal. <br /> EHD believes the following additional information is needed to evaluate the proposed <br /> corrective action and directs you to provide contaminant mass estimates, supported by <br /> calculations, for both sorbed and dissolved MTBE, gasoline, and benzene at this site. <br /> Include a fate and transport model for each of the three substances to assist EHD to <br /> evaluate the risk posed by the sorbed contaminants. Submit the mass estimates, along <br /> with the fate and transport models,to EHD by December 24, 2004. If the site is now well <br /> characterized, several methods for the remediation should be evaluated and presented in a <br /> corrective action plan(CAP); if the site is not adequately characterized but the model <br /> shows a need for immediate remedial action,the proposed actions should be presented as <br /> an interim remediation plan. YI/c <br /> By letter dated January 7, 2004, EHD requested clarification concerning the calculation 1/1� <br /> for the plume volume submitted in Site Conceptual Model. It appears that porosity was V . <br /> inadvertently omitted from the plume volume calculation. Please include a revision or <br /> clarification of this calculation along with the mass estimate calculations and the fate and <br /> transport models on December 24, 2004. <br /> Please contact Vicki McCartney,REHS, at(209)468-3456 or vmccartneyQsicehd.com, <br /> if you have any questions regarding this letter. <br /> Donna Heran,REHS,Director <br /> Environmental Health Department <br /> Nuel C.Henderson,Jr.,RG <br /> Vicki McCartney,R-E---HSt7 LOP/Site Mitigation Unit IV <br /> LOP/Site Mitigation Unit IV <br /> c: David Blakely, CSI <br /> James L.L. Barton, CVRWQCB <br />