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n <br />P <br />t <br />Y <br />August 26, 1992 <br />Ms Nancy K. Lancaster <br />Compliance Unit, Surveillance <br />Dept. of Toxic Substances Control <br />Page 3. <br />Mr. Duane Gelster received the Rescoping Proposal, and <br />verbally informed us that he would not be able to delegate the <br />review of the proposal until the DISC increased its staff, <br />anticipated at the earliest to be in July, 1992. In September and <br />October of 1991 Mr. Gelster discussed with Ms. Cummings the <br />possibility that the DTSC O&M Inspection team, which was on the <br />site in October of 1991, might have the personnel qualified to <br />review and comment on the Rescoping Proposal. However, it turned <br />out that the 0&M Inspection team was not authorized to review the <br />proposal. Mr. Gelster retired in April 1992, at which time we <br />began working with Mr. Wade Cornwell. <br />In June, 1992, Forward submitted the Article 5 Technical <br />Report to the DTSC and the Regional Water Quality Control Board. <br />This report was prepared in compliance with revisions to Title 22 <br />and Title 23 of the California Code of Regulations which require <br />operators to show how they will comply with the newly revised <br />regulations. The April 1991 Rescoping Proposal was incorporated in <br />the Article 5 Technical Report, and included in the appendix. Mr. <br />Cornwell has informed us that the Article 5 Technical Report and <br />accompanying Rescoping Proposal will be reviewed as soon as <br />additional staff can be hired, but with the State's current budget <br />troubles he does not know when this will happen. <br />Forward, Inc. is anxious for the Article 5 Technical Report <br />and Rescoping Proposal to be reviewed. This review will provide <br />the basis for determining the final post closure cost estimate and <br />corresponding financial assurance amount. If DTSC adopts Forward's <br />recommendations, as Forward believes it should, not only will more <br />useful data be generated, but there will also be a dramatic <br />reduction of our post closure monitoring costs. The post closure <br />ground water monitoring costs for WMU-A would be reduced by as much <br />as 2/3. <br />Based on this probable revision in post closure monitoring <br />costs, the Forward, Inc. post closure trust appears to be over <br />funded. Therefore, we have appropriately delayed additional <br />funding until the determination of the final post closure <br />monitoring requirements is made through the review of the above <br />described reports. Once the final monitoring requirements are <br />determined, the post closure cost estimate will be revised. and <br />submitted to the DISC for approval. In short, Forward has acted in <br />a diligent and compliant manner regarding the post closure cost <br />