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CALIFORNIA REGIONAL WATER <br /> QUALITY CONTROL BOARD <br /> May 9, 1983 <br /> Page Two . <br /> that this hearing was scheduled for a cease and desist order ' <br /> after Senator Garamendi took occasion (without consulting <br /> us and without, apparently, knowledge of the fact that this site <br /> had been repeatedly investigated both by your staff and the <br /> Department of Health Services and the local county and that <br /> local hearings have been held) to urge that a hearing be <br /> set. It is our understanding that this hearing has been <br /> requested by the San Joaquin Farm Bureau Federation and/or <br /> its attorneys and that your staff had* not previously in <br /> dicated any need for such a hearing. <br /> You should also be aware of the fact that the site and <br /> its operators are the subject of. a suit brought by San <br /> Joaquin Farm Bureau Federation in Superior Court. <br /> Accordingly, may we submit the following with respect <br /> to the specific items set forth in the notice. <br /> The notice specifically lists the following threatened <br /> violations. <br /> Violation of discharge specification: A. 6"Group 1 . <br /> waste materials and any water that has contacted the waste <br /> materials shall be contained in the area designated for <br /> group 1 waste disposal" . Upon investigating this matter <br /> we received indication from staff of the Regional Water <br /> Quality Control Board that this matter referred to drilling <br /> muds previously in the evaporation ponds which have been <br /> taken out of the ponds and placed on a group2 area of .the <br /> site. <br /> The history of this matter is that these drilling muds <br /> were removed from the evaporation ponds at the direction of <br /> the Regional Water Quality Control Board. <br /> Prior to removal the site operator checked with the <br /> Department of Health Services as to what could be done <br /> with the mud. The Department of Health Services sampled the <br /> drilling muds and indicated they were non-hazardous. The <br /> site operator then moved the muds to a group 2 area for <br /> drying. it is our understanding and to the best of our <br /> information and based on that understanding and information <br /> and belief .we allege that the consultant for the Farm Bureau <br /> then called the Regional Water Quality Control Board staff <br /> which then, after the muds had been moved at- their direction, <br />