SITE INFORMATION AND CORRESPONDENCE

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WASTE DISCHARGE REQWEMENTS ORDER NO. 5-01-148 • -5- FOX VALLEY CORPORATION AND FOX RIVER PAPER COMPANY RIPON MILL SAN JOAQUIN COUNTY semi-perched zone will improve as a result of the lowered TDS in the plant discharge. A report discussing the effect of the discharge on TDS in the three water-bearing zones was submitted in May 1997 and is due every five years thereafter. The review submitted in 1997 indicated that TDS in the semi-perched aquifer diminished during the period from 1992 to 1997, except along the western property boundary and near the northeastern corner of the facility. TDS in the upper flow zone appears to have increased. Based on these results, Fox River Paper Co. has recently installed four additional wells and is completing additional evaluation. 23. The Discharger will continue ground water monitoring to confirm that its discharge with a limitation of 1100 mg/l TDS is not impacting or causing further degradation of the ground water. INACTIVE SLUDGE IMPOUNDMENT CLOSURE 24. The Discharger has elected to conduct in-place closure of the inactive sludge impoundment and has submitted a closure plan (RMT, February 2001). The sludge has been demonstrated to be an inert waste and is therefore not subject to regulations in CCR Title 27. The Closure Plan has been reviewed and the Regional Board has indicated general concurrence with the Plan (letter dated 23 April 2001). The Plan indicates that closure activities will commence within 120 days of Regional Board "approval of the closure plan" and shall be completed within 180 days of commencing work. Formal approval of the Plan has not been provided because the Discharger has classified the waste as inert. 25. Closure will be accomplished by consolidating and passively dewatering the sludge. A ditch around the perimeter of the sludge will allow drainage of the wastewater to a sump at the south end of the inactive impoundment. The sludge wastewater will be routed to the drainage line that flows to ASB No. 2. Sampling of the sludge wastewater will be conducted to monitor the influent to ASB No. 2 and to assure that the effluent limitations from ASB No. 2 to irrigation and percolation fields are not exceeded. 26. After consolidation and dewatering, the sludge mound will be covered with a 1-foot-thick soil layer that will serve as a final vegetative layer. The cover soil will be taken from the existing northeastern berm area, allowing stormwater drainage into the existing Overflow Pond 1. 27. The Discharger will perform routine monthly inspection of the final cover to check for evidence of settling, subsidence, erosion or other potential problems. The perimeter ditches will also be inspected. 28. The closed impoundment will remain non-irrigated open space with no structures in the closed impoundment area or on top of the waste.