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Mr. Robert Trommer - Page 5 of 5 ` Comments on CUF Site Closure Recommendations December 15, 2011 CUF Claim No. 17713 (Rollins Truck Leasing, 28501 E. Loomis Road, Stockton) — in Final Closure Process. The EHD is in process of preparingthe case closure summary and the pending site closure notifications. Monitoring wells must still be destroyed and certificates of disposal for IDW received before the site closure letter can be issued. Summary The CUF table with sites previously elevated to the LOP Director shows that the initial time estimates to complete the closures were too optimistic; therefore, the EHD makes the following timeframe estimates for your consideration: • In Final Closure Process sites are anticipated to be closed between a few weeks for sites well along in the closure process (waiting for certificates of disposal of IDW) to six months for sites just going into the final closure process (closure notifications and case closure summaries issued). • In Closure Process sites are generally assumed will take as long as the In Final Closure Process sites with additional time allowed for tf a notification period and other document preparation, totaling six to nine months for closure. • Report Needed sites can be anticipated to require as much time as the In Closure Process sites plus an additional three to six months of time for report preparation, submission and review, totaling nine to twelve months for closure. Please be assured that the EHD is moving to close t I ese sites as rapidly as possible, yet the timing on much of the closure process is not in the direct control of the EHD. Additionally, the review time for closure requests is taking longer than usual due to the very high volume of cases. This volume is expected to increase with the adoption of the Low-Threat Site Closure Policy. Although the EHD sets deadlines for submitting report s, these are not always adhered to and monitoring well destructions and IDW disposal certificates are not always submitted promptly, despite repeated phone calls and emails. The report preparation and/or well destruction delays are commonly aggravated by the current economic environment and fallout from the cash flow problems confronting the CUF. One consultant seriously proposed an 18-month well destruction program to enable recycling of a limited budget through repeated reimbursements. Thank you for the opportunity to comment on the clos re recommendations. If you need more information to complete your evaluation of these casesi' please contact Nuel Henderson at (209) 468-3436, or by electronic mail at nhenderson(a)sicehdJcom. Sincerely, Donna Heran, REHS Nuel C. Henderson, Jr., PG Director Engineering Geologist