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Mr. Jerry Yoshioka <br />August 18, 1995 <br />Page 3 <br />B3. Completion of a Source Reduction Plan <br />CTL has requested that Sierra -Pacific develop a proposal for completion of CTL's existing <br />Source Reduction Plan. Sierra -Pacific anticipates that the proposal will be submitted to <br />CTL for review by August 23, 1995. Upon acceptance of the proposal, Sierra -Pacific <br />anticipates that four weeks will be necessary to complete the Source Reduction Plan. <br />Anticipated Completion Date: September 25, 1995 <br />C. REQUEST FOR EXTENSION <br />On behalf of CTL, Siena -Pacific is requesting a 60 -day extension to address and implement the <br />identified compliance items. The extension would allow CTL to: <br />• Locate and schedule training programs within the months of August and September; <br />• Develop and implement a medical surveillance program; <br />• Evaluate Sierra -Pacific's Source Reduction Assistance Proposal; <br />• Gather and provide Sierra -Pacific with the necessary annual hazardous waste <br />generation information; <br />• Allow Sierra -Pacific to develop and distribute the Source Reduction Program; and <br />• Provide CTL the opportunity to modify its existing inspection program. <br />The compliance completion dates presented in Section B are anticipated to take less than 60 -days. <br />However, training schedule conflicts with employees and the availability of training sessions could <br />delay completion of the training requirements. A 60 -day extension would provide CTL the <br />flexibility to ensure that the subject compliance items are properly addressed. Should the extension <br />be granted, a completed Tiered Permitting Certification of Return to Compliance would be submitted <br />to your office no later than October 16, 1995. <br />