SITE INFORMATION AND CORRESPONDENCE_1992

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-3- control districts , local environmental health agencies , and other responsible federal , state, and local agencies: (1 ) promotes effective protection of water quality, human health, and the environment and (2) is in the best interest of the people of the state. The principles of coordination are embodied in many statutes , regulations , and interagency memoranda of understanding (MOU) or agreement which affect the State and Regional Boards and these agencies ; 13. Under Executive Order 0-55-86, DTSC and State Water Board entered into an MOU datea August 1 , 1990 which specifies each agency' s responsibilities in hazarcous waste site cleanup; 14. 1n order to clean up and abate the effects of a discharge or threat of a discharge, a discharger may be required to perform an investigation to derive the nature and extent of the discharge or threatened discharge and to develop appropriate cleanup and abatement measures; '5. ?nvesti,-ations that were not properly planned have resulted in increases n overall costs and , in some cases , environmental damage. Overall costs have increased when original corrective actions were later found to have had no positive effect or to have exacerbated the pollution. Environmental damage may increase when a poorly conceived investigation or cleanup and abatement program allows pollutants to spread to previously unaffected waters of the state; 16. A phased approach to site investigation should facilitate adequate delineation of the nature and extent of the pollution, and may reduce overall costs and environmental damage, because: (1 ) investigations inherently build on information previously gained; (2) often data are dependent on seasonal and other temporal variations; and (3) adverse consequences of greater cost or increased environmental damage can result from improperly planned investigations. and the lack of consultation and coordination with the Regional Water Board. However, there are circumstances under which a phased, iterative approach may not be necessary to protect water quality, and there are other circumstances under which phases may need to be compressed or combined to expedite cleanup and abatement; 17. Preparation of written workplans prior to initiation of significant elements or phases of investigation, cleanup, and abatement generally saves Regional Water Board and discharger resources. Results are superior, and the overall cost-effectiveness is enhanced; 18. Discharger reliance on qualified professionals promotes proper planning, implementation , and long-term cost-effectiveness of investigation, cleanup, and abatement activities. Professionals should be qualified, licensed where applicable, and competent and proficient in the fields pertinent to the required activities. California Business and Professions Code Sections 6735, 7835, and 7835. 1 require that engineering and geologic evaluations and judgements be performed by or under the direction of registered professionals;