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California Regional Nater Quality Control Board <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Terry Tamminen Arnold Schwarzenegger <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://wtivw.swrcb.ca.gov/rwgcb5 <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 <br /> 26 July 2004 RRECENED <br /> Pat Mickelson J U L 2 8 2004 <br /> Fox River Paper Company, Ripon Mill <br /> 942 South Stockton Avenue ENVIRONMENT HEALTH <br /> Ripon, CA 95366 PERMIT/SERVICES <br /> NOTICE OF NONCOMPLIANCE <br /> REVIEW OF ANNUAL 2003 AND 1sT QUARTER 2004 MONITORING AND REPORTING <br /> PROGRAM REPORTS, FOX RIVER PAPER COMPANY'S RIPON FACILITY(SITE), SAN <br /> JOAQUIN COUNTY, FACILITYNO. 5B392011002 <br /> We have reviewed the Annual 2003 and 1" Quarter 2004 Monitoring and Reporting Program Reports as <br /> certified by Pat Mickelson and prepared by CA Registered Geologist,David L. Kirk of Lawrence & <br /> Associates. We have determined that the Annual 2004 Report is incomplete, therefore, in <br /> noncompliance with Waste Discharge Requirements Order No. 5-01-148,which includes Standard <br /> Provisions and Reporting Requirements, August 1997(Standard Provisions). Please respond to the <br /> following minimum requirements: <br /> Annual Report <br /> 1. The Standard Provisions require the Annual Report include: "A comprehensive discussion of the <br /> compliance record, and the result of any corrective actions taken or planned which may be <br /> needed to bring the Discharger into full compliance with the waste discharge requirements." and <br /> "A written summary of the monitoring results, indicating any changes made or observed since <br /> the previous annual report." <br /> Time series graphs and Stiff diagrams are referenced in the Attachments section of the Annual <br /> Report,but the text of the report does not include a comprehensive evaluation of the annual water <br /> quality results. The evaluation should include trends in the data for all constituents of concern <br /> (COC) over the past year and historically, as applicable. For instance, monitoring well TH-8 <br /> shows a significantly increasing trend in EC from the 3rd quarter sampling event(787 µmhos/cm) <br /> as compared to 4th quarter event (1,060 µmhos/cm). An explanation for this spike in EC should be <br /> included in the evaluation. The Board's letter of 24 October 2003 addressed this issue as quoted <br /> herein: "Regional Board staff recommended Fox River sample and analyze all COCs in the plant's <br /> waste water as the potential source(s), which should be performed and included in the Annual <br /> 2003 report along with an evaluation of the data with regards to impacts to groundwater." <br /> In the absence of Water Quality Protection Standards (WQPS), it is advisable to compare water <br /> quality to applicable numeric or narrative Water Quality Goals referenced in the Water Quality <br /> Control Plan, San Joaquin and Sacramento River Basins (Basin Plan). The Basin Plan and Water <br /> California Environmental Protection Agency <br /> cci Recycled Paper <br />