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Mr., R—bertTrommer Page 6,of5. <br /> J <br /> Comments on CUF Site Closure Recommendations December 15, 2011' <br /> f <br /> Ct1F Claim No. 17713{kollins Truck Leasing 2850 E. Loomis Road <br /> Stockton) in Final <br /> MdSli re Prtoces$. The FHD is in process of preparing the case closure summary .and the: <br /> pending site closure notifications.. 'Monitoring wells mush still be destroyed and certificates of <br /> disposal for[DW received before the site closure letter can.be issued. <br /> I <br /> Summa <br /> The CUA table with sites previously elevated to the LOP Director shows that: the ,initial time <br /> i estimates:to complete the closures were too optimistic; therefore., the EHD makesle the following <br /> timeframe estimates for your consideration; <br /> o In FinalClosure Process:sites are anticipated to be closed between a few weeks for <br /> sites. well along in the closure process (wait* for certificates of disposal of IDw.7 to:six <br /> months for sites just going intoi 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 tirne allowed for the notification period and other dbcunient- <br /> preparation, totaliiig 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 s.ix months of time for report preparation <br /> submission and revieirl/, totaling:nine to twelve monthS:fo.r 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.. Addifionally, `the <br /> review.time.for closure'reg Tests is taking i;onger 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' <br /> re not,always submitted promptly, <br /> despite repeated phone calls and email5: The report 'preparation and/or well destruction, delays <br /> are:commonly aggravated by the current economic environment"and "fallout fromthe cash flow <br /> problemson <br /> confronting 'the:CUE.One-consultant seriously proposed 'an 18'-month well destruction <br /> program to enable recycling:of a Iirrited 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,, f these cases; please contact Nuel Henderson at (209) <br /> 468-3436., or by electronic:mail at rihende.rson s cehd=�com. <br /> Sincerely, <br /> Donna Heron, REHS Nuel G. Henderson, Jr., PG <br /> Director Engineering Geologist <br />