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LAWRENCE <br /> & ASSOCIATES <br /> ENGINEERING GEOLOGY 0030} 1.00 <br /> CIVIL ENGINEERING <br /> GROUNDWATER HYDROLOGY <br /> March 9, 2006 <br /> Mr. Todd Del Frate <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 11020 Sun Center Drive#200 ENVI :'''•': �`�i I� ALTH <br /> '' <br /> Rancho Cordova, CA 95670-6114 PERIviIT/SERVICES <br /> Dear Mr. Del Frate: <br /> SUBJECT: RESPONSE TO NOTICE OF VIOLATION LETTER OF <br /> FEBRUARY 21, 2006 <br /> This letter is written in to response to Regional Water Quality Control Board (Regional <br /> Board) comments made in correspondence to Mr. Jim Kluesener of Fox River Paper <br /> Company(FR), Ripon Mill, dated February 21, 2006 (attached). In the letter, you <br /> deemed that both of FR's 2nd- and 3rd-quarter 2005 groundwater-monitoring reports <br /> were incomplete, therefore, in noncompliance with Waste Discharge Requirements <br /> (WDR) Order No. 05-01-148. FR was requested to respond to the following items: <br /> Item 1: "Dissolved oxygen (D.O.) is not being reported as required by Waste Discharge <br /> Requirements(WDRs) Order No. 05-01-148, Discharge Specification C.3. Aeration <br /> Stabilization Basins (ASB)No. I and No. 2 erre required to have D.O. measurements of <br /> no less than 1.0 mg/L to comply with WDR, Discharge Specification C.2." <br /> Upon review of WDR No. 05-01-148, no requirement to monitor or report D.O. levels in <br /> ASB No. 1 or No. 2 could be found. WDR Discharge Specification C.2. states that <br /> "Objectionable odors originating at this facility shall not be perceivable beyond the limits <br /> of the property boundary" and Specification C.3. states "As a means of discerning <br /> compliance with Discharge Specification C.2., the dissolved oxygen content in the upper <br /> zone (1 foot) of waste water in ASB No. 1 and No. 2, shall not be less than 1.0 mg/L. As <br /> the aeration devices in both ponds are in continuous operation, and no objectionable <br /> odors are present, it is the opinion of both FR and Lawrence & Associates that no <br /> violation has occurred. However, per our conversation on February 24, 2006, FR will <br /> begin to monitor and report D.O. levels in both ponds on a monthly basis. <br /> ort does not discuss p <br /> quarter d rre <br /> Item 2: 'The Board staff Has not notified and the 3q <br /> the improper destruction of well OB--5 within the text portion of the report Also, the well <br /> was not labeled as destroyed or "not .sampled" (NS) in the appropriatefigures.figures. This is a <br /> violation of the MRP for not requesting apprewal to modify, the existing monitoring <br /> system or for not properly destroying the well in accordance with San .loaquin County <br /> Public Health Services or Department of Water Resources water well standards, " Item 2 <br /> 2001 Market Street • Room 523 • Redding, California 96001 • (530)244-9703 • fax (530)244-5021 • www.lwrnc.com <br />