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Staff Report <br /> Forward, Inc. (continued) -2- <br /> As a result of inspections and evaluations of the Forward, Inc. disposal site, <br /> staff noted the following items that violate or will violate requirements <br /> of Order No. 73-183: <br /> Monitoring of ground water was inadequate, <br /> Solar evaporation pond #5 was used without authorization. <br /> Ponded water was observed on trench caps Nos. 1 and 2. Standing water <br /> was also observed on the Group 2 disposal area. <br /> Heavy equipment storage and traffic occurred on the clay caps for dis- <br /> posal Trench Nos. 1 and 2. <br /> Drilling mud and brines were removed from the solar ponds and placed on <br /> top of the Group 2 disposal area and on the clay cap for disposal Trench <br /> No. 2 without authorization. <br /> A small quantity of barium-strontium sludge was placed in an unlined <br /> excavation between disposal Trench Nos. 3 and 4. <br /> Inadequate control of surface water runoff was provided. There was no <br /> segregation between clean runoff and the runoff that may come in contact <br /> with the drilling muds presently on the clay cap for disposal Trench <br /> No. 2. This .caused a potential overflow situation in the solar ponds <br /> which collected the runoff. <br /> On 12 April 1983, the Executive Officer, under authority delegated by -the <br /> Board, ordered Forward, Inc. to submit a detailed time schedule of specific <br /> actions to correct or prevent violations specified above. On2 May 1983, <br /> Forward, Inc. submitted a time schedule to comply with that order. <br /> By modifying the time schedule submitted by Forward, Inc. to include specific <br /> dates for compliance and reports, to substitute monitorinq well number 16 <br /> for monitoring well number 12, to provide for the elimination and excavation <br /> of the solar evaporation ponds, and. to relocate and properly dispose of wastes <br /> received from FMC, Modesto, staff believes that performance of the specific <br /> actions proposed by Forward, Inc. will correct or prevent a' violation of <br /> Order No. 73-183, and that adoption of an order to cease and desist is <br /> unnecessary. See.Attachment 4. <br /> Conclusions: <br /> 1 . Forward, Inc. has operated in a manner that violates or will violate <br /> discharge Specifications A.6, A.7, A.9, and A.11 , and Provisions B.l <br /> and B.6 of Order No. 73-183. <br />