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#6 "There was inadequate freeboard (less than 2 feet) in the <br /> solar evaporation ponds" <br /> RESPONSE <br /> Each of the solar evaporation ponds is connected to the next <br /> adjacent pond by pipes which are installed at an elevation to <br /> provide two feet of freeboard on the perimeter containment embank- <br /> ments. During the site inspection, no one measured the freeboard <br /> in any of the ponds but apparently formed opinions regarding <br /> freeboard by noticing that the fluid levels were near the top of <br /> the partition embankments. As previously discussed, these embank- <br /> ments are not designed to provide containment but to act as <br /> baffles to allow settling of solid fractions of the waste. The <br /> perimeter embankments provided two feet of freeboard in every <br /> case. It would seem that before such a condition is listed as a <br /> "violation" , a positive physical measurement should be made by <br /> the individuals who made the site inspection. <br /> #7 "The clay caps on top of completed trenches #1 and #2 are <br /> not adequately graded to prevent ponding of water" <br /> RESPONSE <br /> Unusually heavy rains during the winter months of 1981 and <br /> 1982 resulted in surface water control difficulties on the site. <br /> In every case following a rain storm, ponded surface water was <br /> 7- <br />