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l <br /> • RECENED <br /> APR - 2 2007 <br /> LAWRE,NCE ENVIROKiEN HEN H <br /> & ASS0CI \''FES PERMIT/SERVICES <br /> ENGINEERING GEOLOGY <br /> CIVIL ENGINEERING 003044.00 <br /> GROUND-WATER HYDROLOGY <br /> March 28, 2007 <br /> Mr. Todd Del Frate <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 11020 Sun Center Drive 4200 <br /> Rancho Cordova, CA 95670-6114 <br /> Dear Mr. Del Frate: <br /> SUBJECT: RESPONSE TO DRAFT REVISED MONITORING AND <br /> REPORTING PROGRAM NO. 5-01-148 <br /> This letter presents Neenah Paper FR, LLC's (Neenah Paper's) proposed changes to the <br /> text contained in the Regional Water Quality Control Board's (Regional Board's) Draft <br /> Revised Monitoring and Reporting Program No. 5-01-148, Fox River Paper Company, <br /> Ripon Mill, Ripon, San Joaquin County, dated February 5, 2007. As you have been made <br /> aware, the purchase of Fox River Paper Company, LLC (Fox River) by Neenah Paper, <br /> Inc. was finalized on March 1, 2007 at which time Fox River became a subsidiary of <br /> Neenah Paper, Inc. Effective April 1, 2007, Fox River's name is being changed to <br /> Neenah Paper FR, LLC, so all references in the Revised Monitoring and Reporting <br /> Program (MRP) should reflect that new name. <br /> The suggested changes proposed by Neenah Paper are as follows: <br /> Page 2, Section 4, Response to a Release <br /> This entire subheading should be struck from the document. The paragraph <br /> describes the actions required to be taken by the discharger if it is determined that <br /> a statistically significant release of constituents of concern has occurred from a <br /> waste management unit (WMU). The paper sludge contained in the site's WMUs <br /> has been demonstrated to be an inert waste and is therefore not subject regulations <br /> in CCR Title 27.1 <br /> Page 3, Section 6, Submittal Dates, Groundwater Monitoring Reports <br /> The report due date for the annual summary report should be changed to January <br /> 31 from January 30. <br /> 1 Page 5, item 24, California Regional Water Quality Control Board Order No. 5-01-148, dated 14 June <br /> 2001. <br /> 2001 Market Street Room 523 Redding,California 96001 0 (530)244-9703 fax(530)244-5021 9 info@lwrnc.com <br />