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t <br /> x <br /> CALIFORNIA REGIONAL WATER <br /> QUALITY CONTROL BOARD <br /> May 9, 1983 <br /> Page Five <br /> meet the discharge specifications have been taken" This <br /> violation is allegedly based on the use of solar evaporation <br /> pond #5 without authorization. We have submitted construction <br /> plans and. soil liner specifications for approval by the Board. <br /> The staff has indicated that one side of the pond liner needs <br /> to have a 3' thick liner instead of 2' and the staff has <br /> granted conditional approval of the use of that pond with <br /> the understanding that the remedial work will be completed <br /> in the near future. As a more general solution, however, <br /> please be advised that Forward, Inc. no longer intends to <br /> take drilling muds or salt water brines in the solar evaporation <br /> ponds. <br /> The report indicated a violation of provisions B6 "The <br /> discharger shall comply with the monitoring and reporting <br /> program #73-183 as specified by the executive officer" <br /> Upon investigation we are informed that this violation is <br /> based on "frequent submittal" of quarterly monitoring reports <br /> late. We have indicated that we shall submit quarterly <br /> monitoring reports on time. In defense of past late submittals , <br /> may we point out that we have frequently had the requirements <br /> for items to be monitored changed. Additionally, the <br /> exhasutive requirements necessitate frequent use of in-. <br /> dependent laboratories , which in turn add delay to the <br /> reporting process. <br /> The above constitutes our response to the notice; we <br /> will amplify or supplement this as required at the hearing. <br /> We believe, as stated in the RWQCB staff report of <br /> March 25, 1983, that there is no ground water quality <br /> degradation, nor is there any threat thereof. <br /> We hope that the hearing will be limited to the <br /> issues indicated we do reserve the right to respond to <br /> comments made by other parties. Since we do not know <br /> what will be presented by other parties, we cannot submit <br /> our response by May 9, 1983, but will respond as appropriate <br /> at the hearing. <br /> V ry truly yours, <br /> JOHN W. STOVALL <br /> for <br /> NEUMILLER & BEARI)SLEE <br /> A PROFESSIONAL CORPORATION <br /> JWS/djk <br /> ccs Gregory Basso <br /> Jack McCullough �•� <br />