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California Regional Waterualit PontrolQ y Board <br /> Central Valley Region = <br /> Winston H.Hickox Steven T.Butler,Chair <br /> secretary for Cray D2vis <br /> Environmental Sacramento Main Office Governor <br /> Internet Address: http://www.swrcb.ca.gov/-rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(91 G)255-3000•FAX(91 G)255-3015 <br /> 16 November 2000 <br /> Mr. Mike Owens <br /> Fox River Paper Company, Ripon Mill <br /> 942 South Stockton Avenue <br /> Ripon, CA 95366 <br /> GROUNDWATER INVESTIGATION, FOX RIVER PAPER COMPANY, RIPON, SAN JOA QUIN <br /> COUNTY(Case File No. 449) <br /> Regional Board staff has completed review of the Addendum to Work Plan for Continuing Subsurface <br /> Investigation for Fox River Paper Company's Ripon Facility, Ripon, California. That letter was dated 7 <br /> September 2000 and was submitted by your groundwater consultant, Mr. David Kirk of Lawrence & <br /> Associates. The addendum was written in response to my comments dated 24 August 2000. Mr. Kirk's <br /> responses are adequate except for items 7, 8, and 9 regarding compositing soil samples for Volatile <br /> Organic Compound analyses and disposal of soil cuttings. I have discussed these items with Mr. Kirk- <br /> via <br /> irkvia telephone on 13 November 2000. <br /> I have two concerns regarding the responses to Items 7, 8, and 9. The first is in the sampling method <br /> described in the addendum. While it is acceptable to analyse a composite sample from any given <br /> stockpile, mixing large quantities of soil in the laboratory or in the field, even if the soil is placed in <br /> three or more layers within a single tube, is not acceptable for VOC analyses because the mixing process <br /> will cause volatilization of the contaminants. Rather, the samples from the stockpile should be <br /> collected in separate containers (jars or tubes) from which the laboratory can then remove a given <br /> aliquot of soil to composite with other samples from the same stockpile. The second concern is that if <br /> Fox River determines that the soil cuttings from drilling are a designated waste because of VOC <br /> concentrations, and that onsite aeration of soil is appropriate, spreading soil onto land surface for <br /> treatment by aeration would be regulated by Title 27 as a Land Treatment Unit. Land Treatment Units <br /> are referenced in several sections of Title 27, including sections 20080, 20377, 20435, and 21420. <br /> These Title 27 sections require that all facets of Land Treatment Units be regulated, including siting, <br /> permitting, test plots for treatment,monitoring of soil and soil pore liquid, construction and final <br /> closure. For such a small quantity of soil, offsite disposal at an approved facility would probably be a <br /> preferable and more cost-effective alternative. <br /> Transporting soil cuttings from offsite drilling locations along public roads to the Fox River facility <br /> must be in compliance with federal, state, and local requirements. <br /> Your consultant's responses to items 1 through 6 and 10 through 13 are adequate. In regards to item 2, <br /> evaluation of an electric log along with the field geologist's interpretation of subsurface conditions will <br /> be appropriate in determining the screened interval for proposed well TH-11. Please have your <br /> consultant telephone me prior to drilling and conducting the electric logging to inform me of the dates of <br /> each. Surveying the elevations of the top of the well casings with respect to mean sea level is <br /> California Environmental Protection Agency <br /> Ca Recycled Paper <br />