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Page 3 of 5 <br /> problems. <br /> As for a SCM, typically the EHD requires one of these updated/submitted any time <br /> significant feild work redefines the plume characterization as the site prepares for <br /> remedial action implementation. Once a site is IN remediation, most of, if not all of, the <br /> data we need is included in a Status report....whether quarterly or semi annually <br /> submitted. <br /> contrary to some, the EHD does take into consideration the logic of lesser reports on <br /> stable, non-modified remedial systems. If you can support conditions (trends over time <br /> are very supportive), and you feel less report submittal is applicable, then by all means, <br /> request a change. <br /> just keep the EHD in the loop on all changes for this site. <br /> as for this site, all 33 wells are on semi annual. So within 15 days of the ending of the <br /> semi-annual period, the report should be on GT. Additionally, the Geo Well (DTW <br /> sheet) and the laboratory data (EDF) for this same period should be submitted to GT. In <br /> order to meet the 15 day period, we strongly recommend you don't wait till the END of <br /> the semi annual period to START your sampling. with six months in a semi annual <br /> period, doing the sample collection should take place in the first half of it. this allows you <br /> cheaper lab turnaround times and your company more time to generate the report. THIS <br /> is what should be for all previous periods. The resolution took affect around Summer <br /> 2009. after this I'm looking for semi annual submittals. before this, I'm looking for 4 <br /> quarters per year for EDFs, Geo-Wells, and QMRs... <br /> The remedial status report is to include most of the things about the system/site that a <br /> person NOT familiar with the site, could read and understand what's going on. <br /> Additionally, op times, influent-effluent data, repair history as well as standard maps, site <br /> history, and CONCLUSIONS and RECOMMENDATIONS for future/next reporting period <br /> are to be included. Currently, this report is due on GT within 15 days of the end of the <br /> quarter. Again, good planning/prethought, allows for timely uploads. If you're planning on <br /> requesting a reduction, be prepared to support with historical data that shows a trend. <br /> just imagine you are the regulator or the DTSC or EPA reviewer. What would you like to <br /> see in this, one of many reports your read, so that you have a pretty secure feeling on <br /> what's going on there. <br /> more questions? <br /> let me know. <br /> mike. <br /> From: Jeremy Gniffke [mailto:gniffke34@atc-enviro.com] <br /> Sent: Thursday, July 29, 2010 2:07 PM <br /> To: Mike Infurna [EH] <br /> Cc: 'Jean Covington' <br />