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Page 3 of 4 <br /> �►' W <br /> drilling if necessary. <br /> Thank you, <br /> Jackie <br /> From: Mike Infurna[EH] [mailto:MInfurna@sjcehd.com] <br /> Sent: Monday,January 24,20114:02 PM <br /> To:Jackie Lanzon <br /> Subject: RE: 800 West Church Street-boring permit <br /> Jackie, <br /> I've been reviewing your work plan and MFR in preparation for issuing the boring permit and I have <br /> some concerns. <br /> This site is considered a new site since the legal actions have taken place. As such, and in addition <br /> to the papers/fees you already submitted, you'll need to address the following before I can issue the <br /> permit: <br /> 1- a MFR is needed for the'site', so we have a responsible party billing party identified for all NON <br /> drilling work and <br /> 2- a 'permit' MFR is also needed so we have a billing party for all work associated with issuing and <br /> conducting the inspections linked to the permit. any additional EHD charges the initial permit fees <br /> submitted do not cover are sent to the billing party identified on the'permit' MFR. <br /> You submitted ONE MFR....is it a 'site'or 'permit' MFR? or do you want it to be both? It can be.. <br /> if GeoSyntec is accepting 'site'and 'permit'charges billed out by the EHD, then your one MFR <br /> submittal is fine? if not, I'll need another signed MFR before I can issue the permit. <br /> 3- 1 tried calling that phone number you listed on the MFR. No one at this number seems to know <br /> anything about drilling, reports, or anything else I asked. You neglected to include a name of a <br /> contact at"The Newark Group"that can assist me. Please provide the name and an accurate phone <br /> number. <br /> 4- 1 noticed the work plan is UNsigned and undated. oversight? legal move? Something GeoSyntec <br /> doesn't do? <br /> Although you mentioned that the temporary probes will be destroyed after the samples are collected, <br /> you neglected to include that this would be done the SAME day as the probes were installed. This <br /> needs to be clearly called out. Please update the work plan so this is clearly stated. <br /> Dealing with legalities resently, I have learned oversights such as these are interpreted in court rooms <br /> as conditions that allow for exemptions if I allow them to proceed at issuance time. <br /> additionally, and worth mentioning here, is the small print on the bottom of the MFR that you signed. <br /> You signed agreeing all regulated activities will be performed in accordance with our Ordinance <br /> Codes. and the biggy, you "authorize the release of any and all results and environmental <br /> assessment information to SJCEHD as soon as it is available and at the same time it is provided to <br /> me(you)or my representative"..I emphasize this point because I still haven't gotten ALL the <br /> data/reports from the last two phases of work done under permit or NOT done under an <br /> SJCEHD permit at this site. a condition I do not wish to be repeated. Our permit is issued with <br /> conditions that allows you to drill. Your signature constitutes agreement with these conditions(release <br /> data/reports)and compliance to our Ordinance Code. If compliance to our Ordinance Code and/or <br /> releasing data/reports to the SJCEHD is within your authority, then someone else with this authority <br /> needs to sign our MFR. Same for the work plan date and signature. <br /> This sites history, added to unsigned, undated work plans and unclear dates of combined drilling and <br /> destruction of probes/borings has me concerned. I need to have a high level of confidence previous <br /> inadequate procedures won't be repeated, legal explanations or not. <br /> 1/31/2011 <br />