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RESPONSE <br /> Prior to using any Group 1 waste disposal trench at the <br /> Forward site an inspection was conducted which included staff of <br /> the Regional Water Quality Control Board, the State Water Resources <br /> Control Board, the San Joaquin Local Health District and site <br /> management personnel. At that time, we resolved the problem <br /> associated with sand stringers in the disposal trenches by provid- <br /> ing liners for any sand outcrops which occur in the lower 7 feet <br /> of the trench wall. It was the opinion of geologists and engi- <br /> neers from the State Water Resources Control Board that, since <br /> each trench is equipped with a leachate collection system, liners <br /> would only be required in the lower 7 feet. This was possible <br /> because accumulated leachate would not be allowed to develop to <br /> depths above the 7 foot level. All members of the inspection <br /> party concurred in this procedure and the details were documented <br /> in subsequent memoranda describing the site inspection. This <br /> design criteria has been continued in Group 1 waste trenches one <br /> through three and we intend to follow the same design criteria in <br /> Group 1 waste trench #4 which is currently under construction. <br /> An examination of documentation relating to this issue can be <br /> obtained from the Regional Water Quality Control Board, from the <br /> State Water Resources Control Board and from files in the San <br /> Joaquin Local Health District. It is our opinion that this <br /> comment being listed as a violation represents a misunderstanding <br /> of regulatory action that has been taken in the past but which <br /> appears to be misunderstood by regulatory personnel . <br /> -5- <br />