CORRESPONDENCE_1982-1983 - Laserfiche WebLink

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J , g ROUTE 2 • ®OX 605 • WOODLAND. CALIFORNIA 95695 • PHONE (916( 662.6816 April 30, 1982 Mr. Richard W. Konia_ 305 North El Dorado Street Stockton, CA 95202 Dear Sir; We have investigated the activities of Forward, Inc. inasfar as the public records permit. The enclosed findings are either taken directly from the records of the California Regional Water Quality Control Board, Central Valley Region (Regional Board) or are logical inferences of those records. We find that Forward, Inc. is: 1. In violation of the RegionalBoard's requirement for pond permeability. In one case, the pond is 800 times as permeable as the Regional Board's requirement. Based on their reports, it appears that seepage has already allowed enough pollutants to enter the groundwater system to ruin one year's supply for 10,80C persons. If not abated, this number could increase substantially. 2. In violation of the Regional Board's requirement that the quantity and quality of leachate in the Grade 1 Trenches be recorded monthly. The records seem to indicate that these leachates bathed the Grade 1 toxic wastes for a matter of months. Substantial quantities appear to have seeped into the groundwater system, either through the bottoms of the Grade 1 Trenches or through the leaky ponds. Because of the . failure of Forward, Inc. to report according to the Regional Board's requirements, we do not know the extent of this damage. 3. In violation of the RegionalBoard's requirement that the leachates be treated as Grade 1 wastes. (Grade 1 wastes commonly contain toxic substances) Thus, the water of dubious quality was pumped into leaky ponds from which it could percolate into the groundwater system. 4. In violation of the Regional Board's requirement relating to monitoring wells, and possibly some requirements of the Department of Health Services. While the above findings are distressing, we have been shocked to find that the violations have been, in large measure, either ignored or condoned by the staff of the State Water Resources Control Board and the Regional Board. For example: 1. The State Board staff recommended that the leaky evaporation ponds be used, even though they were as much as 800 times as leaky as the'requirement. 2. Regional Board staff appears to have ignored the failure of Forward, Inc. to report as specified in the Discharge Requirements. 3. Regional Board staff appears to condone the leakage of brines into the groundwater system. 4. Among other things, the State Board staff displays an alarming naivete about the deva4inect of bri gh water tables on agriculture. uly. Baier, President DCB:csb