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Mr, Robert Trommer Page 5 of 5 <br />comments on CUF Site Closure Recommendations December 15, 2011 <br />CUF Claim No. ?17713, (Rollins Truck Leasing, 2850 E. Loomis Road, Stockton) — in Final <br />Closure. Process, The EHD is in process of preparing the case- closure summary and the <br />pending site closure notifications. Monitoring wells must still be destroyed and certificates of <br />disposal for IDW.received before the.site closure letter can be issued. <br />Summary <br />The CUF table with 'sites previously elevated to the LOP Director shows that the initial time. <br />estimates to complete the closures were too optimistic; therefore; the EHD makes the following <br />timeframe estimates for your consideration: <br />e In Final Closure> Process sites are anticipated. to be closed between a few weeks for <br />sites well along in the closure process (waiting for certificates of disposal of IDW) to six <br />months for sites just going into the final closure process (closure notifications and case <br />closure summaries issued). . <br />o.. In CiosurefProcess sites :are generally assumed will take as long as the In Final Closure <br />Process sites with additional,time allowed for the notification period and other document <br />preparation; totaling 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 six months of time for report preparation, <br />submission and review, totaling nine to twelve months for closure. <br />Please be assured that the EHD is moving to close these sites as rapidly as possible,. yet the <br />iiming on much of the closure process is not in the direct control of the EHD. Additionally, the <br />review time.for closure requests is taking longer 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 not. always submitted; promptly, <br />despite repeated phone calls and emails. The report preparation and/or well destruction. delays <br />are commonly aggravated by the current economic environment and fallout from the cash flow <br />problems confronting the CUF. One consultant seriously proposed an 1$' -month well destruction <br />program to enable recycling of a limited 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 of these cases, please contact Nuel Henderson at (209) <br />468-3436, or by electronic mail at nhenderson0).sicehd.com-. <br />Sincerely; <br />Donna Heran, REHS <br />Director <br />Nuel C. Henderson, Jr., PG <br />Engineering Geologist <br />