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Mr. Robert 0. Godwin Associate Director The deadlines for exemptions compiled a mailing list fro storage containers conducted ment owners two times in the your surface impoundment un 13173 and 13174); but because facility in time to notify passed. in HUMMEMMEM from specific provisions of the TPCA have passed. We m the inventory of underground hazardous substance in 1984 and notified all potential surface impound - last year about the TPCA. You should have registered der that registration program (Water Code, Sections you did not register, we did not find out about your you of the exemption provisions before the deadline Section 25208.4 of the TPCA states that since your surface impoundments are within one-half mile upgradient of a potential source of drinking water, you will have to close your impoundment by 30 June 1988. For your information, I have enclosed a copy of the Toxic Pits Cleanup Act. The TPCA requires that a hydrogeological assessment report (HAR) be prepared for your facility where liquid hazardous wastes are discharged (25208.7(b) and 25208.8). BY MEANS OF THIS LETTER, WE ARE REQUESTING THAT YOU SUBMIT THE REPORT BY 17 AUGUST 1987. THE REQUIREMENTS FOR THE CONTENT OF THE HAR ARE SPECIFIED UNDER SECTION 25208.8. In accordance with Section 25208.9(a), you will be liable civilly in a sun of not less than one thousand dollars ($1,000) and not more than ten thousand dollars ($10,000) for each day the HAR has not been submitted to the Regional Board. An outline of necessary HAR elements is enclosed. Each point in the outline should be addressed and all conclusions contained in the HAR should be fully substantiated. The discussion in each HAR should include a description of equip- ment, methods, and procedures used, as well as the rationale for their use. Information contained in a HAR should be presented in written, tabular and graphic format, and should be at an appropriate level of detail. All tabular data should be expressed in customary units of measure and arranged so that data (constitu- ents, concentrations, etc.) are readily discernible. Plans, diagrams, and other graphics should be prepared at an appropriate scale and each should include a legend identifying the information presented. All sources of data used in a HAR should be completely and properly identified. If a reference is from an obscure source or is not generally available, the relevant material should be included verbatim as an appendix to the HAR. A qualified person shall be responsible for the preparation of each HAR and shall certify its completeness and accuracy, as specified in Section 25208.8 and Sub- section 25208.8(1) (10, 11). Section 25208.2(t) the TPCA defines a qualified person as being "...a person who has at least five years of full-time experience in hydrogeology and who is a certified engineering geologist ... a registered geologist...or a registered civil engineer...". We are available to meet with you to discuss your proposed work plan to meet the requirements of TPCA. Our review of your work plan will provide you with early input prior to submission of the HAR. The work plan for our review should be submitted by 17 April 1987.