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SITE INFORMATION AND CORRESPONDENCE_1993-1996
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2900 - Site Mitigation Program
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PR0506203
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SITE INFORMATION AND CORRESPONDENCE_1993-1996
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Last modified
3/31/2020 3:10:16 PM
Creation date
3/31/2020 2:30:54 PM
Metadata
Fields
Template:
EHD - Public
ProgramCode
2900 - Site Mitigation Program
File Section
SITE INFORMATION AND CORRESPONDENCE
FileName_PostFix
1993-1996
RECORD_ID
PR0506203
PE
2960
FACILITY_ID
FA0007271
FACILITY_NAME
LINCOLN CNTR ENV REMEDIATION TRUST
STREET_NUMBER
0
STREET_NAME
PACIFIC
STREET_TYPE
AVE
City
STOCKTON
Zip
95207
CURRENT_STATUS
01
SITE_LOCATION
PACIFIC AVE
P_LOCATION
01
P_DISTRICT
002
QC Status
Approved
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SJGOV\sballwahn
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EHD - Public
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include technical, legal, and internal administrative costs <br /> directly related to such oversight, monitoring, commenting, or <br /> participation in the remedy selection process. <br /> Under Section VII-B, the Plaintiff has chosen Dr. Anne <br /> Farr and Kennedy-Jenks Consultants as technical advisors. The <br /> law firm of Hopkins & Carley has likewise been retained to <br /> provide the advice to Plaintiff LPL. However, the Consent Decree <br /> fails to delineate the respective roles of legal counsel on the <br /> one hand, and technical advisor on the other. As a result, the <br /> Equipment Manufacturers are concerned about the possibility of <br /> overlap and duplicative, unnecessary billing in the absence of <br /> such delineation which could be sought to be recovered from them <br /> in the future. <br /> For example, without an explicit delineation of <br /> responsibility, there is nothing to prevent legal counsel from <br /> physically "monitoring" all aspects of technical work at the Site <br /> (and billing for this effort) , including routine drilling and <br /> sampling which would more appropriately be monitored solely by <br /> Plaintiff LPL's technical consultant. This provision is <br /> particularly troublesome in view of the requirement of Section <br /> XVI that all costs incurred pursuant to this Decree are <br /> "automatically" deemed "consistent with the NCP" without any <br /> further review. <br /> The Equipment Manufacturers must also point out the <br /> apparent conflict between the terms of this Consent Decree and <br /> LA\16207\031\5000MDCG.002 <br /> -9- <br />
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