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% <br /> Mr. Robert Trommer Page 5 of 5 <br /> Comments on CUF Site Closure Recommendations December 15, 2011 <br /> CUF Claim No. 17713 (Rollins Truck Leasing, 2850 E. Loomis Road, Stockton) — in Final <br /> Closure Process. The EHD is in process of preparing the case closure summary and the <br /> pending site closure notifications. Monitoring wells must still be destroyed and certificates of <br /> disposal for IDW received before the site closure letter can be issued. <br /> Summary <br /> The CUF table with sites previously elevated to the LOP Director shows that the initial time <br /> estimates to complete the closures were too optimistic; therefore, the EHD makes the following <br /> timeframe estimates for your consideration: <br /> • In Final Closure Process sites are anticipated to be closed between a few weeks for <br /> sites well along in the closure process (waiting for certificates of disposal of IDW) to six <br /> months for sites just going into the final closure process (closure notifications and case <br /> closure summaries issued). <br /> • In Closure Process sites are generally assumed will take as long as the In Final Closure <br /> Process sites with additional time allowed for the notification period and other document <br /> preparation, totaling six to nine months for closure. <br /> • Report Needed sites can be anticipated to require as much time as the In Closure <br /> Process sites plus an additional three to six months of time for report preparation, <br /> submission and review, totaling nine to twelve months for closure. <br /> Please be assured that the EHD is moving to close these sites as rapidly as possible, yet the <br /> timing on much of the closure process is not in the direct control of the EHD. Additionally, the <br /> review time for closure requests is taking longer than usual due to the very high volume of cases. <br /> This volume is expected to increase with the adoption of the Low-Threat Site Closure Policy. <br /> Although the EHD sets deadlines for submitting reports, these are not always adhered to and <br /> monitoring well destructions and IDW disposal certificates are not always submitted promptly, <br /> despite repeated phone calls and emails. The report preparation and/or well destruction delays <br /> are commonly aggravated by the current economic environment and fallout from the cash flow <br /> problems confronting the CUF. One consultant seriously proposed an 18-month well destruction <br /> program to enable recycling of a limited budget through repeated reimbursements. <br /> Thank you for the opportunity to comment on the closure recommendations. If you need more <br /> information to complete your evaluation of these cases, please contact Nuel Henderson at (209) <br /> 468-3436, or by electronic mail at nhenderson@sicehd.com. <br /> Sincerely, <br /> Donna Heran, RENS Nuel C. Henderson, Jr., PG <br /> Director Engineering Geologist <br />