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Mr. Mike Owens 0 - 2 - 1 June 2000 <br /> minimum of three casing volumes be purged from the well prior to sampling, unless the well <br /> recovery is so slow that the well purges dry. Additionally, prior to sampling the field sampler <br /> should demonstrate that parameters such as pH, temperature, EC, and turbidity have stabilized to <br /> within 10% for three consecutive measurements. <br /> 3. The certified analytical laboratory reports shall include the method detection limits and the <br /> practical quantitation limits derived by the laboratory for each analytical procedure. <br /> 4. Laboratory quality assurance/quality control reports shall be submitted with the laboratory data. <br /> 5. It is reported that the only pumping from wells PW-4 and PW-5 occurs during sampling events. <br /> However, field data recorded by the sampler indicates that approximately 20,000 gallons of water <br /> is pumped from PW-4 each quarter. Please explain this discrepancy in the next regularly <br /> scheduled quarterly submittal. <br /> 6. Purge water is discharged to the ground surface near each well. This is only acceptable if the <br /> discharge complies with the effluent limits and discharge specifications of Waste Discharge <br /> Requirements Order# 96-219. A portion of the-Nestle volatile organic constituent (VOC) plume <br /> underlies the Fox River property and groundwater from any VOC impacted wells should not be <br /> discharged to the irrigation fields. Please confirm compliance with the WDRs prior to any <br /> discharge. <br /> Please correct these deficiencies during future sampling events. <br /> Additionally, for the inactive pond closure, your consultant indicates that groundwater collected on 9 <br /> February 2000 from monitoring well OB-11 was analyzed for dioxins and furans. The groundwater <br /> samples were collected by Lawrence and Associates during the regularly scheduled quarterly monitoring <br /> event, however, the analytical reports were not included in the quarterly report already submitted for the <br /> first quarter of 2000. As you indicated in our telephone conversation on 24 May 2000, RMT is <br /> compiling this data and will forward it to me. As I have stated in a separate letter to you regarding the <br /> workplan for the inactive pond area, this data shall be submitted by 19 June 2000. <br /> In August 1999, I commented on several aspects of the groundwater monitoring and corrective action at <br /> the Fox River Paper Mill. I received your fax response on 23 September 1999. The response letter from <br /> Fox River Paper Company requested an extension until 31 January 2000 to respond fully to my <br /> comment numbers 14, 15, and 16. 1 have not received further communication from Fox River Paper <br /> Company regarding these responses and a separate letter that describes possible enforcement actions for <br /> continued non-compliance is being sent to you regarding this issue. <br /> If you.have any questions or comments, please contact me at (916) 255-3137. <br /> WENDY W. ARANO <br /> Associate Engineering Geologist <br /> Attachments <br /> cc. Ms. Alison Youngblood, San Joaquin County Environmental Health Division, Stockton <br />