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Mr, Robert Trommer Page 6 of 5' <br /> Comments on CUF Site Closure Recommendations December 15, 20'11 <br /> CUF C aim No. 1`7713 (Rollins Truck Leasing; 2850 E. Loomis Road, Stockton) ,—i 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 /> l disposal for IDW received.before the.site closure letter can.be issued. <br /> ayMmary <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 EHp makes the following <br /> timeframe estimates'for your consideration' <br /> In F'i`nal 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 summariet.issued). <br /> In Closure Process-sites are generafly 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 bo 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 nixie to twelve m6hthsJor closure. <br /> Please be assured that the EHD 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 control of the 'EHD. .Additionally, the <br /> review time for closure're-quests.is taking longer'thafi iusOal due to the very NO volume of cases. <br /> This volume is ,expected to increase, with the: adoption of the Low-Threat.Site Closure Policy. <br /> Althdugh -the EHD sets deadlines for submitting reports, these-.`aro not:always adhered to and <br /> monitoring well destructions:and IOW disposal certificates are not always. submitted promptly., <br /> despite repeated phone, calls nd aetnails.'The report preparation and/or well destruction delays <br /> are commonly aggravated by the current economic enVir.Qtlment and foilo.ut from. the cash flow <br /> problems confronting the CUF. One consultant seriously proposed;an 18-month well destruction <br /> program to enable recycling of 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-oval uation of these cases; please contact Nuel Henderson at (209) <br /> 468-3436.; or by el.ectronic.mail at,nhendersori scehd;cor�. <br /> Since:rel:y.; <br /> Donna Herein, REHS Nuel C. Henderson, Jr., PG <br /> Director Engineering Geologist <br />