SITE INFORMATION AND CORRESPONDENCE

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FOX RIVER PAPER COMPAORIPON -2 - SAN 2 -SAN JOAQUIN COUNTY Since then, the Board again requested Fox River develop concentration limits based on background in order to develop Water Standards by letter dated 24 October 2003. Based on this historical information and the current status of the site, Board staff believes that we have exhausted our efforts in resolving this issue in an attempt to bring Fox River into compliance with the minimum standards set for in Title 27 CCR and the Water Quality Control Plan Sacramento/San Joaquin River Basins (Basin Plan). We appreciate your efforts to improve your process wastewater,but we are now at a point where we must go forward with ensuring that your waste water quality meets the minimum standards set forth in Waste Discharge Requirements Order No. 5-00-148 which state: E. GROUND WATER LIMITATIONS The discharge, in combination with other sources, shall not cause underlying ground water to be degraded, or: 1. Contain waste constituents in concentrations statistically greater than receiving water limits, where specified below, or background water quality where not specified. (For purposes of comparison, background water quality shall be determined when background monitoring provides sufficient data. Quality determined in this manner establishes "water quality protection standards.") 2. Contain taste- or odor-producing substances in concentrations that cause nuisance or adversely affect beneficial uses. 3. Contain concentrations of chemical constituents in amounts that adversely affect agricultural use. Based on E.2. and E.3. above, we propose water quality goals that would be most protective of the designated beneficial uses of the water. In the case of groundwater underlying the Fox River facility the WDRs specify that the beneficial uses of the groundwater are municipal, industrial and agricultural supply. The applicable water quality goals therefore are as follows: Specific Conductance 700 µmhos/cm Total Dissolved Solids 450 mg/l Sulfate 250 mg/l Chloride 106 mg/l The concentrations for specific conductance (EC), total dissolved solids (TDS), and chloride are derived from Agricultural Water Quality Goals. However, the California Department of Health Services has established secondary Maximum Contaminant Levels (MCL) for each of these constituents as well. The goal for sulfate is a state and federal secondary MCL and is also established by the US Environmental Protection Agency as a taste and odor or welfare criteria for the protection of Human Health and Welfare.