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had not been approved for additional Group I wastes, Forward, Inc. <br /> pumped 450 barrels (18,900) gallons) of leachate from Trench #2 <br /> and transferred it to evaporation pond #1 during the first week <br /> in April, 1980. The leaky condition of the evaporation ponds has <br /> been documented in this report (pp. 7 & 8) , and the fact that the <br /> leachates have been bathing the toxic substances in the trenches <br /> has been described. (p. 10) The conclusion seems inescapable that <br /> a substantial portion of the toxic substances from Grade 1 Trench <br /> #2 has already seeped into the groundwater system, where it will <br /> one day poison someone's water supply. The toxic substances that <br /> have not yet seeped into the groundwater system are almost surely <br /> lying in the evaporation ponds, merely waiting to be flushed into <br /> the groundwater system by the next increment of Grade 1 water or <br /> brine. BAX could find no indication that this flagrant action <br /> evoked even a letter of protest from the staff of the Regional <br /> Board who is charged by law with the responsibility of seeing to <br /> it that such things do not happen. <br /> 5. The staff of the State and Regional Boards have displayed an <br /> alarming naivete regarding the disastrous effects of a briny <br /> high water table on agriculture. <br /> in the memo of April 18, 1980 from Jim Parsons to Frank McDer- <br /> mott (appendix C) Mr. Parsons makes the following remarkable state- <br /> ment, when referring to the percolation of brines from the ponds: <br /> ". ..the substantial thickness of clay present make the . ..problem <br /> not serious..." If BAX interprets this passage correctly, Mr. Parsons <br /> is saying that it is alright for the ponds to leak, provided a clay <br /> layer causes the brines to become parched a foot or two below the soil <br /> surface. * Farmers who have spent thousands of dollars to correct high <br /> water tables will agree that Mr. Parsons' statement exposes his naivete <br /> about the hazard., and if Mr. Parsons is saying that the creation of <br /> a briny water table is not a serious problem, BAX must question his <br /> qualifications to be making this type of decision. As bad as a high <br /> water table is for agriculture, the problem is very much worse if <br /> *BAI has studied the coils and the stratigraphy in the area and does <br /> not agree that there are impervious layers of clay that will protect <br /> the groundwater system. <br /> 13 <br />