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Fox River Paper Company September Ih, 2001 <br /> Response to RWQCD Letter Page 2 of 2 <br /> the FR plant (then Simpson plant). Additionally, that report found that water quality in <br /> the Lower Aquifer is degrading on a regional basis (TDS continues to increase) <br /> throughout the Ripon area at an average rate of 10 mg/L%yea_r, and will continue to <br /> degrade regardless of FR's effluent-disposal practices. The Regional Board concurred <br /> with L&A's conclusions' and that is why all subsequent groundwater models and reports <br /> for the FR plant only address the Semiperched, Upper, and Intermediate Aquifers. <br /> Therefore, it is inappropriate to use values from well TFI-1 as an example of FR not <br /> complying with water-quality goals. <br /> Also in your letter, you state that while"We appreciate Fox River's efforts to improve <br /> 1;+7 <br /> .S ..iui. •.s ,ui:.v.liu.bvs .,� iiia 1_ J'1vVl.L V'ti (kuia1'ia, iAv Wlii a,llvl�iJ.v, <br /> this has riot reduced the concentrations of constituents in the groundwater". This <br /> statement is demonstrably untrue. L&A's Five-Year later-QuaLii�y Report(Five-Year <br /> Report), dated March 20, 2003, concluded that groundwater-quality beneath the site has <br /> generally improved over the past five years. A comparison of water-quality results with <br /> those presented in the previous Five-Year Report(April 1997) shows more onsite <br /> monitoring wells with decreasing (44.4%) or stable(31.1°0) TDS trends (44.4% and <br /> 31.1%, respectively) than increasing TDS trends (24.4%;Five-Year Report, page 7). <br /> Also, a comparison of Stiff diagrams shows more monitoring wells with less-degraded <br /> water quality than observed in the previous Five-Year Report (Five-Year Report, page 9, <br /> Figure 16). In other words, groundwater quality under the site is either stable or <br /> improving in 75% of all wells. If water quality in the Semiperched is solely evaluated, <br /> water quality is stable or improving in over 80% of monitoring;wells. Those monitoring <br /> wells that have increasing trends for TDS are located near the City of Ripon's sewage- <br /> treatment pond (OB-24 and OB-25) or near the northern property boundary (OB-1, OB- <br /> 2, and OB-26), and their increasing TDS trends may not be related to FR's effluent <br /> disposal. <br /> Please call one of us at (530) 244-9703 if you have any questions. <br /> Sincerely, <br /> Michael J. Owens <br /> Eng. &Maintenance Manager <br /> cc: Mr. David L. Kirk,Lawrence&Associates,Redding,CA <br /> Ms.Margaret Lagorio, San Joaquin County Environmental Health Division, Stockton, CA <br /> Mr.Matt Machado, City of Ripon Public Works Department;Ripon, CA. <br /> Mr.Pat Mickelson,Fox River Ripon, CA <br /> Mr.Pete Bertonis,Fox Fiver,Ripon„ CA. <br /> 'RWQCB meeting,March 17, 1992, attended by Kate Harr.son of L&A and Bill Marshall,Robert Evans, <br /> and Scott Walker of the RWQCB. <br /> 0304-3.00 Lawrence&Associates <br /> H.I USERS9R3U(AMSWORD iSchwab Itr Sept 2004rev2.doc <br />