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#5 : "Recently completed solar pond #5 is being used without <br /> prior approval of our staff" . <br /> RESPONSE <br /> As previously discussed, Forward Inc. received approval to <br /> accept drilling muds and brines from the Regional Water Quality <br /> Control Board in 1980 . This approval was documented by the area <br /> engineer (MR. Frank McDermott) and the wastes were considered at <br /> that time to be Group 2 waste, that is, not hazardous. The <br /> approval contained no provision for obtaining prior authorization <br /> from the Regional Water Quality Control Board because Group I <br /> wastes were not involved. Since that approval was granted, there <br /> has been no requirement or documentation which instructed Forward, <br /> Inc. to receive prior approval of the Regional Water Quality <br /> Control Board for construction of new ponds used only for impound- <br /> ment and evaporation of drilling mud wastes and brines. <br /> As previously discussed, these wastes have been accepted in <br /> areas under the jurisdiction of the Central Valley Regional <br /> Quality Control Board in sites which are classified as Class III , <br /> Class 11-2 and Class II-1. To our knowledge, we are the only <br /> facility in this region that provides engineered facilities for <br /> these types of wastes and who monitor for lateral migration in <br /> monitoring wells. <br /> -6- <br />