SITE INFORMATION AND CORRESPONDENCE

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UST Cleanup Claim Number 008.960, Former Drake Property p Mr. Dave Deaner, State Water Resources Control Board February 3, 1995 aware of what he had asked for and received. It is clear that documentation of project status has been clearly and frequently conveyed to the County. It is unclear why, after directives from the County have been adhered to, that the claim from Mrs. Drake has been threatened with removal from the Priority List. If the reasoning for this removal is based on a lack of compliance with County directives, we must evaluate to which set of directives the County is referring. As explained above, Groundwater Technology is confident that the directives for the Site have been more than adequately followed. The situation is complicated by the puzzling interaction between the UST cleanup fund and the authorized lead agency (San Joaquin County Environmental Health Division). As I understand, many counties in California have been authorized by the State to act as a directive body for UST projects. However, in one of my conversations with Mr. Sasson on February 1, 1995 it was clear that the State Water Board was solely responsible for funding decisions, despite the recommendations of Mr. Sasson (the authorized representative at the County). Furthermore, it has been my experience that 90-day response-time letters are the norm when the Fund has determined that a Site is out of compliance. In my conversation with Mr. Sasson on February 1, 1995, he did not understand the justification behind the Fund's issuance of a 30-day response time letter which, when compared to the normal 90-day response time letter, implies a more severe level of non-compliance. In fact Mr. Sasson recommended that a longer response time be granted. The conflict between recommendations from the lead agency and representatives from the UST Cleanup Fund certainly contradicts the authority of County agencies as a directive body for UST sites. Furthermore, it is unclear to us if the stipulated response times in non-compliance letters issued by the Fund are a matter of personal preference or procedure as defined by law. It is clear that in this case the response-time was set by the Fund against recommendations from the lead agency. From a perspective of a project manager at an environmental consulting firm, it is imperative that I provide my customers with the highest quality of environmental service that is possible. If, in this case, the UST Cleanup Fund representatives make unilateral decisions regarding compliance, I recommend that the County be eliminated as the lead agency for the Site. I would prefer dealing directly with the people responsible for my client's funding. My client is a responsible person, who like most small property owners in the state, lacks the funds to cover costs of environmental cleanup, therefore funding from the State is essential. Because the UST Cleanup Fund was established to assist people exactly like my client, it is disturbing that assistance from the Fund has been threatened in this case. I question the utility of an organization (whether it be the County or the Fund) that threatens funding without thorough examination of the she conditions. All the threat has accomplished is undeserved anguish on my client's behalf. 00535pan.Rt GROUNDWATER ��'� TECHNOLOGY .