CORRESPONDENCE_1982-1983 - Laserfiche WebLink

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visit the site. 5. Has written a letter to the San Joaquin County Administrator which states that no serious water quality problems exist at Forward, Inc. That letter was written without, apparently, a careful scrutiny of the records. 6. Displayed an alarming naivete regarding the disastrous ef- fects of a briny high water table on agriculture. CONCLUSIONS Based on the findings of this study, the following conclusions seem inescapable: 1. The operations of Forward, Inc. have resulted in a significant amount of pollution. 2. if changes are not made in the operation of Forward, Inc. the pollution will Increase in the future. 3. The staff of the State and Regional Boards have overtly condoned certain violations of the Regional Board's Discharge Requirements. 4. In other instances, the staff of the State and Regional Boards have not been very diligent in their enforcement of the Regional Board's Discharge Requirements. 5. Saving the groundwater of San Joaquin County from the pollution of Forward, Inc. may require the closing of the site or some sim- ilar vigorous action. EXPLANATIONS AND RATIONALS This section will contain the facts and calculations as well as the rationale upon which the findings and conclusions are based. 1. in direct violation of its Discharge Requirements as set by the Regional Board, Forward, .Xnc. has operated the evaporation ponds without proper lining. A copy of the Regional Board's Discharge Requirements (Order No. 73-183) is attached hereto as Appendix B. Item 12 under "Provisions" states, In part: "The discharger shall follow the recommendations for construction, operation, and maintenance contained in the con- sulting engineer's report dated July, 1972. This shall include placement of a two foot thick clay liner compacted to a permeability of 10-8 cm/sec. or less, underlying the pesticide washwater evaporation pond and leachate collections ...11 (emphasis added) 5