SITE INFORMATION AND CORRESPONDENCE

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• - 2— Pat Mickelson Fox River Paper Company Stanislaus County cannot be set at a level that would exceed the maximum allowable concentrations, or that is to say, applicable water quality goals for the protection of the designated beneficial uses of the groundwater. As shown in the monitoring reports, concentrations of constituents of concern (COCs) and monitoring parameters continue to increase over time in groundwater(i.e., sodium, chloride, EC, sulfate). Background, however, is not well defined. Fox River is required to determine background water quality for each flow zone and should also propose concentration limits as WQPSs for the Regional Board to consider in the Annual 2003 Monitoring and Reporting Program due 30 January 2004. Corrective Action Data clearly shows that COCs are impacting groundwater above water quality objectives described in the A Compilation of Water Quality Goals' and baseline concentrations as shown in several wells (i.e., early data for OB-2). The following are Water Quality Goals for some of the COCs relative to one impacted well for comparison. The Annual report should identify whether other COCl (i.e., metals) are increasing over time, above water quality goals, or above background conditions. WATER QUALITY GOALS Constituent Groundwater Water Quality Goal Average Levels in OB-2Z Monitoring Well Total Dissolved Solids 450 m /L 1340 m L Electrical Conductivity - 700 µmhos/cm 2158 mhos/cm Sulfate 250 m L 288 m /L Sodium 2 m L 120 m L Chloride 106 m L 267 m L *See attached time series graphs showing linear trend lines of increasing levels of COCs as examples (i.e., sodium in TH-7, OB-1 and OB-2; chloride in OB-1 and OB-2; TDS in OB-24; EC in OB-25). The next step in the Corrective Action Program (CAP) is to develop an engineering feasibility study in accordance with Title 27 §20430. In this regard, Fox River will be required to submit an engineering feasibility study within 90 days after the establishment and acceptance by the Regional Board of Water Quality Protection Standards. As discussed in our meeting, identifying the constituents in the plant effluent would be the first step since the discharge is the most likely source of the impacts to groundwater. Title 27 §20430 (c) states, "Scope of Actions—The discharger shall implement corrective action measures that ensure that COCs achieve their respective concentration limits at all Monitoring Points and throughout the zone affected by the release, including any portions thereof that extend beyond the facility boundary, by removing the waste constituents or treating them in place. The discharger shall take other action approved by the RWQCB to prevent noncompliance with those limits due to a continued or subsequent release from the Unit, including but not limited to, source control. The WDRs shall specify the specific measures that will be taken." t The attached memorandum describes how water quality goals are developed for groundwater and surface water depending upon site specific factors,as applicable. 2 OB-2 shows constant increasing levels(trend)in several CDCs since the well was first sampled in 1992.