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STAFF REPORT -2- FORWARD, INC. , CLASS II-1 DISPOSAL SITE SAN JOAQUIN COUNTY In the future, Forward may also be required to provide vadose zone monitoring (the unsaturated zone between the ground surface and the ground water table) under the Group 1 disposal areas. This would provide early detection of pollutants before entering the ground water system. Vadose zone monitoring is not a standard requirement, but may be developed for uniform application by the State Board in the development of Subchapter 15. In addition to providing analysis of Group 1 materials placed in the disposal trenches, Forward will also be required to provide analysis of materials in the solar evaporation ponds. This would ensure that the materials are suitable for disposal in this area. Many of. the proposed revisions have already been implemented by Forward with the exception of the installation of the additional ground water monitoring wells. , Forward has not agreed to a definite date for. installation of the wells. By letter dated 2 November 1982, staff requested plans and time schedule by 15 November 1982 for monitoring well construction. No written response has been received and the discharger has verbally indicated wells will not be completed until adequate revenue is received at the site. Staff recommends that these wells should be constructed according to the schedule contained in the proposed Monitoring and Reporting Program. Existing Requirements Waste discharge requirements for this site need to be revised to reflect policy changes and operational modifications that have occurred since their adoption in 1973. Revised WDRs should also include applicable sections of Subchapter 15 of the California Administrative Code when amendments are completed by the State Board. We understand these amendments will be significant and will necessitate modification of Forward, Inc. , WDRs. Since no ground water pollution at this site is apparent, we plan on delaying WDR modification until Subchapter 15 is revised. Concern has been expressed by Forward, Inc., that the present WDRs are too stringent with regard to nontoxic drilling mud disposal , as compared to other 'dischargers. Forward contends that this results in inconsistent regulation which gives competi- tors an unfair advantage. For example, Forward, Inc., is required to dispose of . muds in lined ponds while the Arcady Oil Class III site (also in the Stockton area) may deposit muds in unlined sumps. The potential water quality threat from nontoxic muds is total dissolved solids (TDS) . The TDS concentration at which serious water quality degradation may occur is a difficult question. In an effort to achieve a better understanding of the situation, staff (1) has consulted with the State Board, (2) plans to increase monitoring of drilling muds sites, and (3) plans to seek input from industry representatives. Fresno staff have met with the Western Oil and Gas Association regarding this matter.