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r <br /> California RRional Water Quality ntrol Board :�.. <br /> Central Valley Region , <br /> u <br /> Robert Schneider,Chair <br /> Terry Tamminen Arnold Schwarzenegger <br /> Secov/rw <br /> g Q <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.swrcb.ca. cb5 D <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 C <br /> Phone(916)464-3291 <br /> AUG 1 6 2004 <br /> 11 August 2004 <br /> ENVIRUNfUEiV-I t1'tf-tri ti <br /> Pat Mickelson/Mike Owens PERMIT/SERVICES <br /> Fox River Paper Company, Ripon Mill <br /> 942 South Stockton Avenue <br /> Ripon, CA 95366 <br /> WATER QUALITYPROTECTION STANDARD REPORT, FOX RIVER PAPER COIVIP4NY, <br /> RIPONMILL, SANJOAQUIN COUNTY, FACILITYNO. 5B392011002 <br /> We have reviewed the Water Quality Protection Standard Report(Report), dated 19 March 2004, as <br /> prepared by Lawrence &Associates. Based on the minimum requirements of Title 27, California Code <br /> of Regulations (Title 27 CCR), Division 2, Subdivision 1, we have determined that the type of statistics <br /> proposed for developing the Water Standards (Title 27 CCR §20390) for the site is inappropriate. <br /> Because of the complexity of the groundwater regime and multiple site dynamics, Fox River has chosen <br /> intrawell analysis using the Mann-Kendall test for trends in the data. Because the site's monitoring <br /> wells were installed after disposal of process water to the ground, the water quality data does not reflect <br /> background conditions. All monitoring wells show impacts from past and current disposal practices; <br /> therefore, are not applicable in establishing Water Standards for the site. <br /> Prior to July 1975, the Fox River Ripon Mill discharged to the Stanislaus River continuously or <br /> intermittently. Since July 1975, the mill has been able to contain all wastewater on land. Background <br /> wells were not established for the site prior to disposal to the ground. As stated in the report, the <br /> practice of flood irrigation of process water creates groundwater mounds in the uppermost three aquifer <br /> zones beneath the site. Several other facilities discharge effluent to groundwater in the vicinity,namely <br /> Nestle to the north and City of Ripon sewage treatment to the west. <br /> Based upon Regional Board's conversation with Lawrence and Associates,we understand that Nestle's <br /> consultants were contacted and offered viable data available to Fox River. Apparently, there is EC field <br /> data available that could be used initially to investigate water quality at specific wells that can be <br /> compared to Fox River data. The Report does not reflect the collection and analysis of this data or a <br /> survey of viable wells on the Nestle property that could be used as background for Fox River. <br /> Our records show that the Board required Fox River submit Concentration Limits as Water Quality <br /> Protections Standards in a letter dated 21 September 1999 (see attached). Subsequently, we issued an <br /> enforcement letter, dated 1 June 2000, again requiring, among other items, "An estimate of the time <br /> needed for groundwater to meet either background water quality or California water quality goals for the <br /> designated beneficial uses at Fox River facility." Subsequently, revised WDRs were adopted that <br /> allowed effluent discharges above the water quality goals and allowed Fox River the opportunity to alter <br /> their processes in order to reduce concentrations of constituents of concern (CDCs) to a minimum. <br /> California Environmental Protection Agency <br /> ca Recycled Paper <br />