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developed by the American Petroleum Institute. This information <br /> was reviewed by staff of RWQCB and they authorized disposal of <br /> drilling mud and brines at the Forward site during March, 1980. <br /> Following authorization to receive these wastes Forward, <br /> Inc. instituted a receiving procedure at the waste site which <br /> includes inspection of all loads of drilling mud and brine; <br /> sampling of all drilling mud and brine from the waste trailer; <br /> examination of each sample for combustible components, for pH, <br /> and finally, physical examination of the sample to insure that it <br /> is, in fact, drilling mud or brine. At no time in the past have <br /> our requirements been that individual analysis be performed on <br /> each load of drilling mud or brine waste. We know of no such <br /> requirement, and there is no correspondence from the Regional <br /> Water Quality Control Board which indicates that such analysis <br /> should be made. <br /> Drilling mud and brine waste are commonly accepted at several <br /> other sites in San Joaquin, Contra Costa, Solano, Yolo and Sacra- <br /> mento Counties. These wastes are accepted at all of these other <br /> sites without these type of analysis being conducted, in fact, <br /> the wastes are disposed of in surface impoundments which are not <br /> engineered or lined; the wastes are disposed of in sites which <br /> are not classified, at all or designated Class III , Class 11-2 <br /> and Class II-1. <br /> #2 : "The liners under the solar evaporation ponds may not <br /> be continuous and may allow vertical and lateral migration of the <br /> -2- <br />