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CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD May 9 , 1983 Page Three indicated that the muds ,wele group 1. The site operator spoke with the staff which indicated that the operator should ensure that the drainage from the mud should be drained back into the solar evaporation ponds. The drainage does go back into the ponds. To resolve this matter we indicate the following: We first attempted to determine why the Regional Water Quality Control Board staff indicated that they were hazardous. We were informed that it was because they contained salt. We asked what salt concentration would render a material hazard or what level indicated Group 1 waste and were told that there was no such number but that these were too salty. To the best of our knowledge and belief there is yet no. determination and standard requirement for a concentration which indicates whether a material is or is not hazardous because of salt content. Nevertheless, we intend to do the following. We intend to take all drilling muds presently on the site, and place them into hazardous waste materials trench #4 (a Group 1 trench) , as soon as trench #4 is completed. As can be seen from our previous correspondence relating to the time schedule, we will need both to complete trench #4 and to dry the muds. With current weather conditions it is difficult to estimate when this task can be completed, however we feel that final disposal of the subject drilling muds can not be accomplished prior to August 31, 1983. You will note that we received comments of the staff on design details of Group 1 trench #4 , reconstruction of the solar evaporation pond liners , and installation of the. ground water monitoring wells by memo- randum dated two days after the letter setting this hearing for cease and desist order. The second alleged violation is; A7 "Waste confinement barriers shall be protected and maintained to insure their effectiveness Upon discussion with the staff, it appears that this alleged violation is based upon the claim that heavy equipment storage and traffic occurred on the clay caps for disposal trenches #1 and #2. To the best of our knowledge and belief there is no lack of effectiveness with respect to the clay caps for disposal trenches #1 and #2. We shall insure that neither heavy equipment storage or traffic occurs on top of the clay caps for any group 1 disposal trenches. (Please note that this alleged violation was mentioned in the staff report of 25 March 1983, the operative paragraph of which was "The report concludes that although there have been a number of technical violations