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UC` ' , BJJ COMPANY, LLC (209) 94,-836, ► In response to BJJ's inquiry, Afforda Test stated the following reasoning for the non-submission and corrective action... "We sent our new tech, Ed Stearns to do your Des Op inspection in the month of November. Environmental Health knows that Afforda-Test has all the tech staff doing Des Ops. We decided not to go thru sending an owner statement because his certification was going to expire in the next month and we would have had to have 100 sites sign and get back to us all those owners statements and then resend 100 again allover again after his recert. We figured we would just recertify him and send anew owners statement after he retook his certification test. At that point we would send our 100 sites all at one time. We did not send him on any inspections after his license expired until he obtained his new recertification. I have talked to the staff at Son Joaquin EH about this in the past and they were fine with the logic of this. I don't know why it is o huge issue now. We will make a point of not doing that again. It is easier than trying to keep up with multiple inspectors'opinions of what makes sense." BJJ expressed to Afforda Test that it is imperative that submission deadlines are met. BJJ had every confidence that as their Designated Operator, Afforda Test would be handling regulatory submissions and required updates. We feel these two violations could have easily been avoided with more attention to administrative details. We also feel this reflects poorly on Afforda-Test, while at the same time take full responsibility of our contractors. As much as possible, BJJ will take a more proactive roll in following up with our UST related required submissions. Please don't hesitate to give me a call if you have any questions or concerns. Regards, Steve Terayskis WGR Southwest, Inc. BJJ Company's EFI&S Consultant POST OFFICE BOX 30010 • STOCKTON, CALIFORNIA 95213-0010