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4 Mr. Jack Hecht -2- 15 January 1987 pollutants are being leached into the ground water from the auto shredder wastes discharged at your site. This is sufficient cause to require that you institute a verification monitoring program (California Administrative Code, Title 23, Chapter 3, Subchapter 15, Sections 2551(a)(2) and 2557). The intent of a verifi- cation monitoring program is to verify that water quality protection standards have or have not been exceeded and to determine the source and extent of the contamination. This program will require that additional water tests be done and may require the installation of additional monitoring wells. A meeting should be arranged to discuss the details of the sampling strategy. The results of the verification monitoring program must be submitted by 17 July 1987. SWAT PROPOSAL Your facility is also affected by Section 13273 of the California Water Code (the Calderon legislation). This requires operators of solid waste disposal facilities to submit a SWAT report to the Regional Board. The intent of the SWAT is to determine if hazardous wastes are leaking from the waste management unit and to assure compliance with Subchapter 15 regulations. To avoid misunderstandings about the requirements of a SWAT report, a proposal must be turned in before any testing is done. A guidance document for preparing a SWAT proposal is enclosed. The Cove Contractor site is in rank number two (2). In accordance with your ranking, you are requested to submit a SWAT proposal by 1 April 1987 or sooner. Since your SWAT and verification monitoring efforts will have considerable over- lap; I suggest that you combine these reports as much as possible. The closure plan for your facility should address the measures that will be necessary to close the site in compliance with the requirements set forth in Article 8 of Subchapter 15. A perusal of the well logs in Kleinfelder's report shows that wastes are in contact and even submerged in water. This is prohibited by Subchapter 15 and must be remedied prior to closure. Other details of the closure plan may be affected by the results of the verification program and the SWAT report. The closure plan is due 3 August 1987 so that it may benefit from the effort invested in the Verification Monitoring Report and the SWAT. We are requesting these technical reports pursuant to Section 13267 of the California Water Code. Failure to submit any of the requested items, An a timely manner, is a violation of state law and may result in formal enforcement action and the imposition of civil liabilities of up to $5,000 per day for each day in which the violation occurs.