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Ms.Lori Duncan • May 17,2001 <br /> San Joaquin County <br /> Page 3 <br /> conducting an expensive investigation using a technology with limited competition and <br /> without the flexibility of available, less costly methods may not be reimbursed by <br /> SWRCB UST Fund <br /> We note that the initial work plan for this phase of work was submitted in January 2001 <br /> and two addenda have been prepared to address the concerns of the SJCEHD/PHS The <br /> concern and request for revised laboratory analysis was successfully addressed in the <br /> initial response, however the continued demand for a specific drilling technology is at <br /> issue The persistent requirement of a specific and limited drilling technology by the <br /> SJCEHD/PHS is delaying the completion of this phase of work <br /> The State Water Resources Control Board established policies for carrying out a phased <br /> step by step investigation to determine the nature and extent of possible soil and ground <br /> water contamination or pollution at a site in Resolution No 92-49 Resolution No 92-49 <br /> specifically includes releases from underground storage tanks Resolution No 92-49 <br /> (Section 18) also specifically references Water Code section 13360 <br /> Resolution No 92-49-Section 18 reads - "WC Section 13360 prohibits the Regional <br /> Water Boards from specifying, but not from suggesting methods that a discharger may <br /> use to achieve compliance with requirements or orders It is the responsibility of the <br /> discharger to propose methods for Regional Water Board review and concurrence to <br /> achieve compliance with requirements or orders" SJCEHD/PHS is a contractor to the <br /> . SWRCB for the enforcement of SWRCB regulations and as such is required to recognize <br /> and implement the policies, including Resolution No 92-49, of the State Board <br /> As the above discussion indicates, Nagab G (Mike) Elsumen and M J Kloberdanz and <br /> Associates have made every effort to comply with the directives of SJCEHD/PHS and <br /> request to be allowed to proceed with the investigation (as described in the work plan and <br /> two addenda) in the manner required by SWRCB Resolution No 92-49 Please call me <br /> at (209) 577 - 8186 if you have any questions about this submission or the Ripona Market <br /> investigation <br /> Sincerely, <br /> Michael J Kloberdanz, A, REHS <br /> M.J. Kloberdanz &Associates <br /> Cc Ripona Market <br /> Attachment <br /> Wp3addmll <br /> i <br />