SITE INFORMATION AND CORRESPONDENCE

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t FOX RIVER PAPER COMPA RIPON • -2 - SAN 2 - SAN JOAQUIN COUNTY Quality Goals may be found at http://Nvww.swreb.ca.gov/i-wqcb5. Once the WQPSs as Concentration Limits (CLs)have been established, the Annual evaluation should include a comparison of water quality with the WQPSs and Water Quality Goals. 2. The Annual Report did not include an electronic version of the data pursuant to Standard Provisions. Please submit an electronic version of all data as noted on the attached Monitoring Report Compliance Checklist(Checklist). WDRs Order No. 5-01-0148, Provisions G.3. states: "The Discharger shall comply with the Standard Provisions and Reporting Requirements, dated August 1997, which are hereby incorporated into this Order. The Standard Provisions and Reporting Requirements contain important provisions and requirements with which the Discharger must comply. A violation of any of the Standard Provisions and Reporting Requirements is a violation of these waste discharge requirements." Please address the above comments in an Addendum to the Annual Report by 1 October-2004. General Comments In order to create a'stand-alone document, we request that subsequent Quarterly and Annual reports include the following information, as applicable: 1. Include a brief description of the regional and Site-specific geology and hydrogeology. 2. Include information regarding adjacent facilities with groundwater contaminant plumes. Discuss whether the contaminant plumes commingle with the Site's groundwater, unsaturated zone, and/or surface water conditions. Include the constituents of concern(i.e., VOCs, SVOCs, TDS). Please include a brief description of any cleanup efforts at adjacent sites, as applicable, and whether the cleanup system impacts the Site's hydrogeologic regime (i.e., groundwater extraction and/or injection). 3. Provide date(s) of closure activities for the Closed Sludge Pond. The current maps show SLUDGE DISPOSAL areas. These maps should be updated to reflect the CLOSED SLUDGE POND and ACTIVE SLUDGE DISPOSAL POND. 4. Please perform a one-time sampling event of sludge "solids"that are disposed in the ACTIVE SLUDGE DISPOSAL POND unless there is historical data showing the waste is inert. This may be accomplished as part of the Annual sludge sampling event as prescribed in WDRs. Include the data and analysis in the Annual 2004 Monitoring and Reporting Program. If there is a proposed material change in the plant process which would change the quality of the sludge, please notify the Water Board as required in Standard Provisions and Reporting Requirements (August 1997), which state: "Before making a material change in the character, location, or volume of discharge, the discharger shall file a new Report of Waste Discharge with the Regional Water Quality Control Board (hereafter Board). A material change includes, but is not limited to, the following: