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had diminished to 3.3 feet. Where did the missing 2.5 feet of fluid <br /> go? Did it seep away, carrying the soluble toxic substances into the <br /> groundwater system? And what about Trench #1, which may have had 6 <br /> feet of water in it in January, but none in April? Did that water, <br /> too, seep into the groundwater system, carrying toxic substances with <br /> it? if Forward, Inc. had complied with its Discharge Requirements, <br /> the amounts of water and the quality thereof would be known, and it <br /> would be easy to determine the extent of the pollution of the ground- <br /> water system. (See the sketch in figure 1.) <br /> It has been pointed out above that the Discharge Requirements <br /> required that the trench linings be compacted to a permeability not <br /> greater than 10-8 cm/sec, in the case of the evaporation ponds, <br /> Forward, Inc. apparently conducted tests to evaluate the permeability <br /> of the lining. In the case of the Grade I Trenches, on the other <br /> hand, BAX could find no record that any test whatsoever had been <br /> conducted on the linings of the trenches, <br /> in spite of the ominous nature of the sketchy information <br /> available, BAX found no evidence of concern on the part of the <br /> staff of the Regional Board. In fact, when BAX first raised the <br /> question regarding the leachates in the Grade I Trenches, the reply <br /> of the Area Engineer, Mr. Robert E. Fujii was that there had never <br /> been any leachates in the trenches. When the appropriate passages <br /> of the Forward, Inc. reports were called to his attention, he readily <br /> admitted his error. <br /> in summary, the records seem to indicate that Forward, Inc. <br /> allowed Grade I wastes containing toxic substances to be immersed <br /> in water in the trenches for a period of at least three months. <br /> During those three months, there seems to be a good likelihood <br /> that a substantial portion of that toxic-laden waste has seeped <br /> into the groundwater system. If there are other explanations for <br /> the disappearance of this water, (BAX estimates 45,000 gallons) the staff <br /> of the Regional Board could not produce them when BAX met with them on April <br /> 16, 1982 to discuss BAI findings. BAI respectfully suggests that the staff <br /> of the Regional Board has not been as diligent as is warranted in this case. <br /> 3. The staff of the Regional Board has written a letter to the San <br /> Joaquin County Administrator which states that no serious water <br /> 11 <br />