SITE INFORMATION AND CORRESPONDENCE

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WASTE DISCHARGE RE*MENTS ORDER NO. 5-01-148 • -4- FOX VALLEY CORPORATION AND FOX RIVER PAPER COMPANY RIPON MILL SAN JOAQUIN COUNTY GROUNDWATER MONITORING 17. Groundwater monitoring is conducted in four flow zones beneath the Fox River Paper Mill. The first encountered groundwater is an unconfined aquifer encountered approximately 35 to 60 feet below ground surface (bgs). Fox River's consultants term this the "semi- perched" aquifer. Twenty-eight monitoring wells have been installed by Fox River, OB-1 through OB-28. Fox River also monitors two wells installed by the Nestle Company, M-7-B and M-11-B. The groundwater gradient in this flow zone is strongly influenced by surface discharges in the percolation fields and flow direction varies dependent on the surface discharge. Some recharge from the Stanislaus River along the southern property boundary is apparent. 18. The second encountered groundwater is the"upper" aquifer, which is encountered between 85 to 110 feet bgs. The groundwater is confined to semi-confined. Mounding is apparent, though to a lesser degree than in the semi-perched flow zone. Wells monitored by Fox River include TH-2 through TH-5, TH-7, TH-9, and TH-11 and two of Nestle's wells, M-7-A and M-11-A. TH-2 and TH-11 are within the central portion of the site. The other monitoring wells are located along the perimeter of the facility. 19. The third encountered groundwater is the "intermediate" zone, which is encountered between 140 to 225 feet bgs. Groundwater in this zone generally flows southeasterly,but exhibits some elevation depressions near the process water supply wells drawing from this zone. Groundwater is confined to semi-confined within this zone. Wells located within this flow zone include TH-6, TH-8 and TH-10,process supply wells PW-4 through PW-8, and Nestle wells M-11-C, M-19-C,M-20-C, and M-20-D. 20. A"lower" or"deep" flow zone has been encountered from about 240 to 300 feet below groundwater. Fox River has drilled only one test hole into this flow zone, TH-1, although some of the process wells may also be screened into this zone. GROUNDWATER DEGRADATION 21. Background groundwater quality at the site is difficult to ascertain due to a plume of pollutants to the north of the site,which originates from the Nestle facility. Also, to the west of the site, the City of Ripon discharges both domestic and industrial wastewater to percolation ponds. Ground water recharge from the Stanislaus River on the south side of the facility, however, is of very high quality. 22. A ground water model evaluated the semi-perched aquifer zone, the upper aquifer zone, and an intermediate aquifer zone. The semi-perched zone had an average TDS of 938 mg/l; the upper aquifer had an average TDS of 566 mg/l; and the intermediate aquifer had an average TDS of 422 mg/l. Over a five-year period,the model predicts that TDS in the