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J�RE09t„FS UNITED STATES ENVIRONMENTAL PROTECTION AGENCY <br /> A Region 9 <br /> g 75 Hawthorne Street <br /> ` San Francisco CA 94105-3901 <br /> C?� <br /> May 18 , 2000 <br /> Mr. Dale Clemens <br /> Environmental Protection Office <br /> DD-Tracy <br /> P.O. Box 960001 <br /> Stockton, CA 95296-0250 <br /> RE: FFA Schedule Compliance <br /> Dear Mr Clemens, <br /> As has been discussed between you and Michael Work of my <br /> staff, the Defense Logistics Agency has not submitted a primary <br /> document (Draft Remedial Action report for Small Excavations) per <br /> the terms of the Federal Facility Agreement (FFA) Schedule. This <br /> schedule was provided to EPA at the RPM meeting of April 12, <br /> 2000 . According to the terms of the FFA, DLA is to request <br /> modifications to any FFA schedule in writing prior to deadline . <br /> Further, such a request is to include the timetable, deadline or <br /> schedule that is sought to be extended, the length of the <br /> extension sought, the extent to which any related deadline would <br /> be affected, and the "good cause” basis for the extension per FFA <br /> Section 9. 2 . <br /> As of this writing, EPA has not received written <br /> notification of any request for extension. The deadline of March <br /> 30, 2000, for the Draft Remedial Action Report for Small <br /> Excavations remains unchanged; thus, it would appear that DLA is <br /> out of compliance with the FFA schedule and potentially <br /> vulnerable to enforcement action, which may include an assessment <br /> of stipulated penalties . <br /> EPA is requesting a formal response from DLA to address this <br /> issue. While this issue remains unresolved, EPA considers the <br />