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_ _ r <br /> Mr, Robert Tromrner Page 5 of'5 <br /> Comments on CUF:Site Closure Recommendations December 15,,2011 <br /> CUF Ciairn No. 17713 (Ftollrns Truck Leasing, 2850E Loomis Road, Stockton) .1 Final <br /> Closure Process. The EHD is in process of preparing the case closure summary .and the <br /> pending site closure nafifications. Mo.ritoring wells must still be destroyed, and certificates of <br /> l disposal for IDW received before the site closure letter can,be issued. <br /> Summary <br /> The .CUF table ;with sites previously e evated'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 fo'r your consideration; <br /> In FinalClosure= 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 IDUV):to six <br /> months for sitesjust;going into the final closure process (closure notifications° and case. <br /> closure summaries i'ssued), <br /> ® In Closure Process..:sites.are generallyassumed will take as long as the In Final Closure <br /> Process sites with additional time allowed for the notification period and either docurrient <br /> preparation, totaling.six tonine months for closure <br /> Report Needed sites ,can be anticipated to :requ.ire as M ch tirne as the In Closure <br /> Process sites plus an additional; three to six months of time for report preparation, <br /> submission andreview, totaling nine to'twelve mo'nths'for closure. <br /> Please be assured that the- EHO is mousing 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.. 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 Pal"i,cy. <br /> .Although the EHD. sets deadlines'for submitting reports,.these are ;not always adhered to and. <br /> monitoring well destructions:and IpW disposal certificates are not always ubmitted.. promptly.,, <br /> despite repeated phonecalls amid `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 theCUF. One consultant seriously proposed:an 18-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.a# (200) <br /> 468-3436, or by electronic mail�at nhenderson sicehd�.g rl . <br /> Sincerely; <br /> <y i' <br /> Donna Heran, REH.S Nuel C. Henderson, Jr., PG <br /> Director Engineering Geologist <br />