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• <br />' Greg Vaughn -2- 26 August 1987 <br />estimated there would be only six weeks to complete the HAR. We <br />were told that Arcady was aware of the HAR deadline and the <br />potential enforcement consequences of a late HAR submittal, but they <br />felt it was the best they could do. They also indicated they <br />believed they would prove they were not subject to the TPCA, once an <br />adequate waste characterization was completed. <br />In summary, the following dates for submittal of information were <br />established: <br />SPPL will submit a technical report by 28 September 1987, <br />summarizing their preliminary site investigation of the gasoline <br />pipeline spill, including results of as yet to be taken monitor <br />well samples. <br />Arcady's consultant will contact me in the upcoming weeks <br />for input into their plan for additional waste characterization. <br />Their plan, incorporating Regional Board input, will be <br />submitted by 1 October 1987. <br />The Solid Waste Assessment Test (SWAT) proposal (due 1 <br />October 1987) will be submitted by Arcady on schedule, however <br />the HAR workplan would be delayed pending additional waste <br />characterization work. <br />Attachment <br />PHL:phl