SITE INFORMATION AND CORRESPONDENCE

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Fox River Paper Co. Iy Iviay cwv Please - 2 - • roun water review the attached Monitoring Report Compliance Checreport. Please ensure subsequeint or the g g andd Reporting monitoring and Annual Summary p Pro ram reports include the necessary information to make them complete and adequate. 9 Report of Waste Discharge Comments The Discharger is stating they cannot establish groundwater bac roan watercentquaolity as n the required in Title 27. In the ROWD, the Discharger had Ripon Area. The Dischargers consultant states, "concentrationTDSconcentrations."within�s backg ound p too large to establish reliable estimates of background o ver can be classified as inert, determination is required so that the wastewater from Foxiwill be determined by the non-hazardous, designated, or hazardous. This classification development of background concentrations for constituents or parametersII datain the vic nityDof the Board staff recommend, the Discharger evaluate groundwater ferwhere the quarterly monitoring. Stanislaus River (River). Especially for Semi-perched �q Based s show groundwater flow from the River onto the site er monitoringlnorthward. ep r t appears on a report g resented in the 4 th quart review of the Time graphs p reasing or wells OB-10, OB-14, OB-16, OB-17, OB-21 and OB-22 have de range between bi1i78 and 748 and EC concentrations ConcentrationsD should behS from used to establish backgrounesed mg/L. Therefore, staff believes these wells concentrations. In accordance with WDRs No. 5-01-148, Section E.1 the Discharger rrediate shall zones.develop For the background concentrations for the semiperched, upper 16, OB-17, OB-21, and OB-22 should semiperched zone, monitoring wells OB-10, OB-14, be used. The Discharger for the upper and intermediate zones shoul data in the vicinity of the Stanislaus River and develop b should uoundsednn est bl�hing oar staff believes the data set from January 2002 forward background concentrations. In accordance with Title 27, Section 20400 (b), Board staff will review the proposed background values and if appropriate establish Water Quality Protection Standards in the g 19 June 2006 the Discharger shall submit facilities Waste Discharge Requirements. By background concentrations for TDS. If background concentrations asdon the Bas submitt e 9 requested date, Board staff will have to establish WQP QualityObjectives for TDS. Once WQPSs are approved and the upwastewater classifie alternatives an p Discharger can then develop appropriate quality impacts beneath the site. ve ish It is Board staff's recommendation the Discharger utilize PSsthe fo the Foxlisted Rive�s'te�n ac olydance background concentrations for TDS and propose WQ with WDRs 5-01-148 by 19 June 2006.