SITE INFORMATION AND CORRESPONDENCE

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Fox River Paper Company - 2 - 21 August 2006 40 East Percolation Field; utilizing low TDS water for paper manufacturing or flood irrigation) would reduce further impacts to groundwater quality beneath the Fox River site. In theory, these continued changes should have a "trickle down" affect through the known aquifers. Board staff concurs with Fox River Paper Company on the following background groundwater concentrations for the semi-perched, upper, and intermediate aquifers establishing Water Quality Protection Standards (WQPS) for the Fox River Ripon Paper Mill. These concentrations will be utilized to evaluate groundwater impacts and the Discharger shall incorporate these groundwater WQPS into future monitoring reports. Groundwater WQPS for the Unit are listed below and will be incorporated in an updated Monitoring and Reporting Program Order No. 5-01-148: WATER QUALITY PROTECTION STANDARDS Constituent of Concern Semi-perched Aquifer Upper Aquifer Intermediate Aquifer Bicarbonate 307 mg/L 482 mg/L 315 mg/L Calcium 51 mg/L 209mg/L 49 mg/L Chloride 178 mg/L 197 mg/L 68 mg/L Electrical Conductance 1242 mhos/cm 1580 µmhos/cm 760 µmhos/cm Magnesium 26 mg/L 43 mg/L 8.8 mg/L Nitrate 4.3 mg/L 4.7 mg/L 5.7 mg/L pH 6.5 - 8.5 6.5 - 8.5 6.5 - 8.5 Potassium 2.6 mg/L 10 mg/L 6.8 mg/L Sodium 184 mg/L 89 mg/L 100 mg/L Sulfate 111 mg/L 150 mg/L 31 mg/L TDS 713 mg/L 1030 mg/L 470 mg/L Under Monitoring and Reporting Program No. 5-01-148, Fox River will determine whether corrective action measures taken are sufficient to clean up the impacted groundwater. Also these standards will be used to determine if the continued discharge of wastewater to land needs to be contained in a waste management unit designed to handle designated waste per California Code of Regulations, Title 27 (Title 27). Presently, effluent wastewater discharged to land contains elevated concentrations of TDS above the accepted WQPS of 713 mg/L. Since the effluent wastewater is above the WQPS and has the potential to impact groundwater, the wastewater is classified as designated waste. In accordance with Title 27, Section 20430(c) which states: "The Discharger shall implement corrective action measures that ensure that COC's achieve their respective concentration limits at all Monitoring Points and throughout the zone affected by the release, including any portions thereof that extend beyond the facility boundary, by removing the waste constituents or treating them in place. The discharger shall take other action approved by the RWQCB to prevent noncompliance with those limits due to a continued or subsequent release from the unit, including but not limited to, source control. The WDRs shall specify the specific measures that will be taken." As a result of the paper manufacturing process, groundwater beneath the Fox River site has been impacted by discharges of process water with elevated concentrations of TDS. Fox River has made efforts to improve the effluent discharge resulting in better water quality