SITE INFORMATION AND CORRESPONDENCE

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Pat Mickelson • Fox River Paper Company 3 Stanislaus County As stated in the MRP, the Regional Board may determine that the waste water should be contained if mitigating measures fail to bring water quality back to Water Quality Protection Standards. Inspection Report Regional Board staff's inspection of the facility found areas of concern that should be addressed by Fox River as follows: 1. Two tanks on the eastern side of the facility were found to be leaking liquid to a drain. Fox River staff stated that the one tank had been repaired, but apparently still had a small leak. The other tank appeared to have a constant leak, as indicated by the algae growing adjacent to the tank. We request Fox River provide information on the source liquid that is leaking, the fate and transport of the liquid, and a timeline to mitigate the leaks permanently. 2. Dead redwood trees were stockpiled in a windrow in one of the orchards on the west side of the facility. Redwood trees are acidic in nature. In order to mitigate any composting issues and potential groundwater quality changes from decomposition, we recommend that the dead trees be recycled. Please provide an action and timeline for addressing this area of concern. Review of 1". 2"d and 3.d Quarter Monitoring and Reporting Program The attached Monitoring Report Compliance Checklist for the groundwater monitoring report itemizes areas of concern. Please ensure subsequent Monitoring and Reporting Program reports include the necessary information to make them complete and adequate. Specifically, the Conclusion portion of the 1" Quarterly report states, "Infiltration of plant process water is likely responsible for the elevated conductivity levels measured in the semiperched aquifer(Figure 5). The sources of the elevated conductivity measured along the northern boundary of the property in the semiperched and upper aquifers are unknown (Figures 6 and 7)." Based on the summarized data and time series graphs there also is a trend of increasing levels in chloride and sodium in the semiperched aquifer. This issue was discussed in the Regional Boards inspection on 21 October 2003 with Fox River staff. Time series graphs are attached to delineate Regional Board's concerns. Early data show that levels of sodium at OB-2 started at 9.2 mg/L in 1992. The highest detection was 1330 mg/L in October 2001 (this does not appear to be an outlier due to other high values in other wells and other constituents). Regional Board staff recommended Fox River sample and analyze all COCs in the plant's waste water as the potential source(s), which should be performed and included in the Annual 2003 report along with an evaluation of the data with regards to impacts to groundwater.