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Testimony of Wayne S. Smith, Ph.D. , Geotechnical <br /> Engineer <br /> Dr. Smith's testimony will include the following matters: <br /> Diagrams and figures of the conditions under <br /> which the liners permit leakage. <br /> ® The permeability values, including whether the- <br /> reported permeability values are the real per- <br /> meability values and whether the tests run and <br /> reported are the tests that- should have been <br /> done. <br /> Inasmuch as the initial calculations of <br /> permeability assume that the water body con- <br /> sists of pure water , Dr . Smith will discuss the <br /> increases in leakage which would be occured <br /> when the water body consists of something <br /> other than pure water. <br /> Soil conditions under the' liner and some <br /> comments on the increase in the rate of <br /> movement of leakage once it gets through the <br /> bottom of the pond liner. <br /> e Operation techniques. <br /> Attached is the resume of r. Smith. <br /> Also attached is a copy of a letter dated May 5, 1983,. from <br /> Richard W. Konig, to John Stovall, Counsel for Forward, Inc. <br /> When that letter is answered, we request an opportunity to <br /> comment on the type of tests performed for Forward, Inc. by their <br /> consultants and to submit a summary report. . <br /> The estimated time for Dr. Smith is ten minutes. <br />