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Eom ND C. BnowN JR. <br /> MATTHEW RORFIOOEZ <br /> CttlAnl 10E <br /> Water Boards `/ ENVRON—TALPR.Tl� pe <br /> Central Valley Regional Water Quality Control Board <br /> C1VE <br /> 8 January 2014 JAN 102014 <br /> ENV1RpNM <br /> Ms. Marie Joachim PERMITSERV�ce <br /> Nestle USA, Inc. <br /> 800 North Brand Blvd. <br /> Glendale, CA 91203 <br /> 2011 REVISED FEASIBILITY STUDY REPORT, FORMER NESTLE USA <br /> INCORPORATED FACILITY, RIPON, SAN JOAQUIN COUNTY <br /> Central Valley Regional Water Quality Control Board staff (Central Valley Water Board <br /> staff) have completed review of the Nestle USA Inc. (Nestle) 2011 Revised Feasibility <br /> Study Report (2011 FS) for the former facility in Ripon, California. Our comments on <br /> the 2011 FS are provided below. These comments are based on our review of the 2011 <br /> FS as well as the discussions between Central Valley Water Board staff and Nestle at <br /> the 12 December 2013 meeting in our office. <br /> Comments <br /> 1. Central Valley Water Board staff concurs with most of the elements of Nestle's <br /> selected groundwater remedy, as presented in the 2011 FS and augmented at the <br /> 12 December 2013 meeting with a hydraulic containment plan for the Upper <br /> Aquifer. These elements that we can presently concur with include pump and treat <br /> in the Upper Aquifer, institutional controls (to restrict new well installations, to <br /> coordinate municipal & other local supply well pumping, to replace impacted water <br /> supply wells, and to decommission vertical conduit wells), and implementation of in <br /> situ treatment (reductive dehalogenation, chemical oxidation/aerobic <br /> cometabolism, permeable/impermeable barriers) as necessary. The selected <br /> remedy also includes intrinsic remediation (monitored natural attenuation) and <br /> relies primarily on this passive action to restore the groundwater, especially in the <br /> Intermediate and Lower Aquifers. We concur that that data collected to date looks <br /> very promising, but it is unclear whether intrinsic remediation will restore impacted <br /> groundwater within a reasonable time frame. <br /> 2. It will likely take several years for Nestle to complete their assessment of intrinsic <br /> remediation. Therefore, Nestle should move forward with preparation of the <br /> Remedial Action Plan (RAP). The RAP should contain contingencies to implement <br /> additional pump and treat and/or in situ remediation to the selected groundwater <br /> KARL E. LO.GLEY SOD, P.E., CHAIR I PAMELA C. CiREEDON P.E., BCEE, EXECUTIVE OFFICER <br /> 11020 Sun Center Drive#200,Rancho Cordova,CA 956]0 I www.waterboardg.C2.gov/centr.lva1ley <br /> C',nevry Leo'All. <br />