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PAGE TWO DISCUSSION OF IMPACTS NOTED ABOVE: l.b. , c. , d. Two ponds have been created on site without benefit of review and permit. Creating these ponds has altered the drainage pattern both on and off-site. A field inspection of April 26, 1990, also revealed a non-permitted discharge of used process water out of the north side of the process plant, which has created a large cut into the hillside. This discharged water contains sediment from the sand and gravel processing, as well as from erosion of the stream bed formed as a result of this unauthorized release. No environmental review was ever done for these two ponds or this discharge of process water, as they were never included in any previous permit or subsequent revision. In their referral response, the Regional Water Quality Control Board stated that the facility is in violation of the California Water Code by not filing a report of waste discharge (RWD) , and discharging without a permit. The letter received from R.W.Q.C.B. noted that during a site inspection a significant amount of silty waste water was being discharged to natural drainage, tributaries to Mormon Slough. It has been noted by the property owner that the used process water is draining downhill, under Waverly Road, and ultimately into the Calaveras River with unknown but potentially significant impacts on these waterways from siltation and sedimentation. Based on this, the R.W.Q.C.B. is requiring that prior to any expansion of the operation, the applicant must show that existing waste water can be managed adequately. 2 .a. , b. The applicants have been dredging one of the settling ponds and dumping the dredged silt and clay onto the outer banks of the pond. Dumping of these silts has resulted in the slope of the pond banks exceeding the 2 : 1 maximum slope set forth in the Planning Title. The pond is also located on a hill crest, and the silt has been dumped over a layer of dry grasses. There is a possibility that this unconsolidated silt material will wash down hill during periods of rainfall, and enter natural drainage channels, ultimately being discharged into the Calaveras River.