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Quarterly Report - 152 East I lth Street, Tracy Page 5 During the reporting period, three Standard Form Payment Requests with detailed supporting documentation were submitted the CSWRCB One payment covering an earlier request for reimbursement was received Initially SWRCB staff indicated that the three most recently requested reimbursement requests would be denied because the approval of that office had not been obtained before remediation work had been initiated It is assumed that this proposed denial of funding came about do to a breakdown of internal communications at the CSWRCB Successive formal submittals of all preliminary and final corrective action plans with copies of letters of direction from the regulatory agencies having legal authority to direct the work were submitted to the SWRCB beginning as early as June 1994 These submittals included completed Cost Pre-Approval Request forms supported by a copy of the CAP, and a professional engineer's estimate The Cost Pre-Approval Request forms were obtained from the SWRCB after repeated request to the staff of that agency who initially insisted that no such standard submittal form existed All of these actions were fully documented in this series of status reports copies, all issues of which had previously been submitted to the SWRCB Also, reimbursement for the cost of implementing the first phases of the CAP, which had been required and approved by the regulatory agencies having legal jurisdiction over the site, had previously been received by the owners without comment by the SWRCB SIn order to be sure that they were in compliance with all applicable laws and regulations, after being notified by the SWRCB that funding for the remediation work was being denied, the owners ordered all work on the subject site halted and requested further guidance from the SWRCB and the SJCPHS The SJCPHS responded in a letter to the owners that confirmed that the remediation was being performed as necessitated by existing California law and under their regulatory direction as the primary agency having responsibility to ensure compliance with all applicable laws and regulations Afler some delay, reimbursement substantiality all of the remediation costs documented by the submitted Standard Form Payment Requests has been received by the owners without comment by the SWRCB Reimbursement for the outstanding amounts will be re- submitted with the next Standard Form Payment Request WORK IN PROGRESS The following work is in progress Remediation Shortly following the close of the reporting period that is the subject of this document, backfilling of the remedial excavation was completed Except for a small area affected by work to restore parts of the public streets and sidewalks where they were involved in the 0 excavation has been returned to the operational control of the owner