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Ms. Margaret Lagorio • • <br /> November 30, 2001 <br /> We are still having trouble understanding why Mike has assigned a due date for a document(a <br /> PAR)that can only be written after site assessment is complete. Per Tri-Regional Guidelines, site <br /> assessment activities are to proceed in phases. Each phase of site assessment work attempts to <br /> define unknowns identified in the work plan. Often the site assessment activities identify new <br /> unknowns and the assessment needs to proceed into additional phases of work. Predicting when <br /> site assessment activities will be complete is not possible and assigning a due date for a PAR is <br /> such a prediction. <br /> It is not clear why Mike Inf mia generally wants the consultant to continue assessment at the site <br /> based on their professional opinion without comment from PHS/EHD, but yet, for the subject <br /> case, Mike does not let the consultant,based on their professional opinion, determine when the <br /> site is ready for a PAR. Although we have no choice but to operate under this inconsistency, we <br /> are nevertheless dismayed that PHS/EHD makes this necessary. <br /> PHS/EHD claims that assessment was not progressing in a timely manner at this site,but we do <br /> not agree. Cambria submitted a site investigation report on March 2, 1999 for this site and never <br /> got a response from PHS/EHD regarding assessment activities. Then on February 27,2001 <br /> SJCPHS issued a letter requesting a work plan and also directing us to submit a PAR by <br /> December, 7, 2001. Nearly two years went by while PHS/EHD did not comment on our <br /> investigation report and then we got a letter requesting a work plan and a PAR. In order for us to <br /> progress in a timely manner with assessment at this site, PHS/EHD needs to review, comment, <br /> and approve(per Tri-Regional Guidelines)of our site investigation reports in a timely manner. <br /> We also have an issue with how Mike Infuma handled a due date that we missed. PHS/EHD's <br /> February 21, 2001 letter was never received by our consultant(Cambria)and was misplaced <br /> within Equiva's files. The fact that we had missed the due date for a work plan that was <br /> specified in the February letter came to our attention quite indirectly. Rather than contacting <br /> Equiva or our consultant to verify we received his letter or ask why we had not submitted a work <br /> plan,Mike called the State UST Fund representative to inform him that we were out of <br /> compliance.The UST Fund representative notified Equiva's Fund coordinator and Equiva's Fund <br /> coordinator notified me. Mike's methodology in this case was inappropriate,unprofessional, and <br /> time-consuming. For the record, Equiva takes due dates extremely seriously and so do our <br /> consultants. If we miss a due date it is for a good reason, not just to delay progress at a site. In <br /> this case the due date was missed because neither my consultant nor I knew the due date existed. <br /> PHS/EHD suggests that CPT boring SB-14 be moved north of MW-1, as if that will further <br /> expedite assessment. SJCPHS further suggests that we could predict the results of December's <br /> upcoming investigation phase in order to determine where additional monitoring wells should be <br /> 2 <br />