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ing body within their regions, and their decisions often have the <br /> effect of law. <br /> Both the State and Regional Boards are served by a staff. The <br /> top staff member, in both cases, is called an Executive Officer. It <br /> is important to point out that the staff does not make policy, nor <br /> set discharge requirements, except when specifically empowered by <br /> the Board to do so. Generally, the function of both staffs is to <br /> carryout the orders of the Board. <br /> FINDINGS <br /> This section of this report will give only a brief outline of <br /> the irregularities discovered by BAI. Detailed explanations and ra- <br /> tionale will be contained in a following section entitled "Explana- <br /> tions and rationale". <br /> BAI finds that Forward, Inc. is in violation of its Discharge Re- <br /> quirements in several significant respects. These are: <br /> 1. The Board's Requirements say that the construction of the ponds <br /> ".. .shall include placement of a two foot thick clay liner <br /> compacted to a- pezmeability of 10-8 am/sec. or less. .." This has <br /> not been done. Present pe abilities are as much as 800 times <br /> this value. <br /> 2. The Board's Requirements say, "The discharge shall not cause a <br /> pollution". The Grade I Trenches have been operated in such a <br /> manner as to allow an unknown quantity of a waste of unknown <br /> quality to seep into the groundwater system. <br /> 3. The Board's requirements say that Forward, Inc. shall '! ..comply <br /> with the monitoring and Reporting Program No. 73-183 . .." That <br /> Abnitoring and Reporting Program states, "Leachate controls shall <br /> be installed for the purpose of monitoring quality and rate of <br /> production of leachate from the fill..." Even though leachates <br /> have been reported in the trenches, no data on quality of the <br /> leachates has ever been provided, and the information on quantities <br /> has been significantly less than the requirement. <br /> 4. The Board's requirements say "Group 1 waste materials and any <br /> water that has contacted the waste materials shall be contained <br /> in the area designated for Group I waste disposal. Forward, Inc. <br /> 3 <br />