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RESPONSE <br /> The permeability of 10 - 6 cm/sec. required by the discharge <br /> requirements is for solar evaporation ponds containing pesticide <br /> rinse water and the leachate collection systems associated with <br /> these ponds. Such ponds have never been constructed on the <br /> Forward site and pesticide rinse waters have never been accepted <br /> for disposal at this facility. <br /> Mr. Baier, as an ex-employee of the State Water Resources <br /> Control Board, should know that the permeability requirements on <br /> Class II-1 sites in accordance with standards * published by the <br /> State Water Resources Control Board are 10 - 6 cm/sec. The <br /> 10 - 8 cm/sec. requirement is for Class I disposal sites . In <br /> fact, this can be seen by examining the second page of Mr. Baier' s <br /> Exhibit C. <br /> The only ponds currently in use at Forward contain rotary <br /> drilling muds and brines from gas and oil wells . According the <br /> the State Department of Public Health Services, these wastes are <br /> not hazardous. This conclusion is supported by recent chemical <br /> analysis conducted by the State Department of Health Services . <br /> These pond facilities at Forward however, have been fitted with <br /> liners and surrounded by embankments which have permeabilities in <br /> the range of 10 - 6 - 10 - 7 cm/sec. as required by standards <br /> *"Waste Discharge Requirements for Nonsewerable Waste Disposal <br /> to Land. " by Alvin L. Franks, Ph.D. , California Water Resources <br /> Control Board, July, 1980, pages 24-27 . <br /> -2- <br />