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Pat Mickelson • 2 — <br /> Fox <br /> —Fox River Paper Company, Ripon Mill <br /> San Joaquin County <br /> 2. Monitoring and Reporting Program Order No. 5-01-0148 requires annual sampling of the sludge <br /> as, "A composite sample of sludge shall be collected annually in accordance with EPA's POTW <br /> Sludge Sampling and Analysis Guidance document, August 1989, and tested for the following <br /> metals and organics: <br /> Cadmium Lead <br /> Chromium Nickel <br /> Copper Zinc <br /> Acetone 2-Butanone" <br /> Table 1 does not include acetone or 2-butanone on the list of constituents. Furthermore, there is <br /> no discussion in the Annual report which references sampling and analysis pursuant to EPA's <br /> guidance. During a conference call on 10 March 2005, with your consultant David Kirk, of <br /> Lawrence and Associates, we decided that EPA's POTW guidance might now not be appropriate <br /> for paper sludge from the Fox River plant. I recommended that we have a conference call to <br /> discuss these issues towards resolution. <br /> In this regard,we request Fox River submit a sampling and analysis plan for annual sampling and <br /> reporting of the solid sludge disposal at the site. Once the plan is found acceptable by Board staff, <br /> we propose to revise the MRP. The MRP is ultimately approved by the Executive Officer. <br /> 3. The Regional Board's review letter/checklist of 26 July 2004 requested Fox River include a form, <br /> certified by signature, for Standard Observations pursuant to Standard Provisions and Reporting <br /> Requirements,August 1997. This was not included in subsequent monitoring reports. <br /> Please respond to our request for copies of the two reports and submit a sampling and analysis plan <br /> (SAP) for solid sludge by 1 June 2005. <br /> A Monitoring and Compliance Program Checklist is enclosed. Please respond to comments itemized in <br /> this checklist in subsequent monitoring reports. <br /> If you have any questions, please contact me at 916-464-4737. <br /> A. SCHWAB, P.G. <br /> Engineering Geologist <br /> Enclosure <br /> cc: Margaret Lagorio/Ray VonFlue, San Joaquin County Environmental Health Division, <br /> Stockton <br /> David Kirk, Lawrence &Associates, Redding <br /> Binayak Acharya, Environmental Cost Management, Costa Mesa <br /> kas:FoxR 2,3,4QA20041tr <br />