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l <br /> Mr.; RobertTrommer <br /> Page 5-of 5 <br /> j Comments on CUF Site Closure Recommendation's December 15,,2011 <br /> 1 <br /> GUF Claim No 17T13 (Rollins Truck Leasing; 285.0 E. Loomis Road, Stockton) — In Final <br /> Closure. Process. The EH'D is in process of preparing :the case :closure surrimary aid the <br /> pending site closure notifications, Monitoring wells must still be destroyed, and certificates of <br /> I disposal for I'DW received before the site closure letter can.be issued. <br /> Summary <br /> The CLIF table with sites previously elevated to the LOP Director shows that:.the .initial time <br /> l estimates to complete the clo ures were too optimistic; therefore, the EHR makes the following <br /> timeframe estimates for your consideration:. <br /> 1:n Final Closure Process sites are anticipatedto be closed between a few :weeks for <br /> sites well along in the closure process (waiting for-certificates of disposal, of ID1N) to six <br /> months for sites just going into the final closure process (closure:notifications and case. <br /> closure.summaries iss'ued), <br /> �. I,n:Glo4ure Process>.sites.are generally assumed will take as long as the In Filial:Closure <br /> Process sites with additional time allowed ,for the notification pe iddzand other document° <br /> preparation, totaling six to nihe months for closure. <br /> R port Needed sites care 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., totalirig nine to twelve:months for closure. <br /> Please be assured that the E:HD:is moving to close these sites as rapidly as possible yet the <br /> timing on`much of the closure process- is not in the direct colitrol of;the EHD Additoirally,-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 adppfion 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 IDtN disposal certificates are not;always.submitted promptly, <br /> despite repeated, phone calls and emails. The report preparation and/or well de: <br /> straction delays <br /> are. commonly aggravated f�y;the current economic environment aril fallouf from the cash flow <br /> problems confronting the CW.r. One consultant seriously proposed an 1'8-month well destruction <br /> program to enable recycling of a limited budget through repeated reirrifiursements. <br /> Thank you for the opportunity to comment on the closure recommendations. If you ne d more <br /> information to complete your evaluation'of these cases; please contact• Nuel Henderson.at (209) <br /> 468-3436, or by.electronic mail,at nhendelson cx s cehd.corn., <br /> __.. <br /> 'Sin cerely, <br /> 1 � <br /> ---'tom"��.'Ya;•---- <br /> Donna Henan, REHS Nuel.C. Henderson, Jr.., PG <br /> Director Engineering Geologist <br /> f <br /> t <br /> i <br />