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2011 Revised FS - 2 - 8 January 2014 <br /> Former Nestle Facility, Ripon <br /> remedy if intrinsic remediation is unable to restore impacted groundwater within a <br /> reasonable time frame. These contingencies must have conservative triggers and <br /> require quick implementation. <br /> 3. The 2011 FS does not discuss Nestle's current pumping plans for the Upper <br /> Aquifer. At the 12 December 2013 meeting, Nestle proposed to install a future <br /> pump and treat system in the vicinity of former municipal well MW-4 in order to <br /> provide containment of their VOCs plume in the Upper Aquifer. Central Valley <br /> Water Board staff concurs with this proposed action for the Upper Aquifer, but it <br /> should be documented in a revision to the 2011 FS or in a new addendum to it. <br /> This revision or addendum should include (at a minimum) an explanation for the <br /> changes to the selected remedy in the 2011 FS, presentation of the modeling <br /> results, and any other pertinent data that support the revised pumping plan for the <br /> Upper Aquifer. We concur with Nestle's proposed remedial plan for the Upper <br /> Aquifer, so we believe this additional documentation can be done in parallel with <br /> preparation of the Draft RAP. <br /> 4. Central Valley Water Board staff support Nestle's proposed further assessment of <br /> intrinsic remediation and encourage you to provide a draft work plan for our review <br /> in the first quarter of 2014. We understand Nestle was planning to submit this draft <br /> work plan with the RAP. However, we believe it is prudent to move forward quickly <br /> with this assessment. Nestle can still submit the final work plan as an addendum <br /> to the RAP. <br /> 5. The 2011 FS assumes reinjection of treated groundwater is infeasible or would <br /> require costly treatment for CoCs that are not attributed to Nestle like nitrate and <br /> total dissolved solids. Central Valley Water Board staff believes additional <br /> treatment for these other CoCs will be unnecessary as long as Nestle injects their <br /> treated groundwater in the Upper Aquifer and at a location that does not adversely <br /> affect containment of their Upper Aquifer plume. <br /> 6. The 2011 FS identifies potential ARARs for groundwater, but does not include <br /> California Public Health Goals (PHGs) for drinking water. These PHGs are <br /> potential ARARs for this site. Nestle needs to either add them to a revision to the <br /> 2011 FS or address this omission in an addendum to the 2011 FS (see General <br /> Comment 3). <br /> If you have any questions, please contact me at (916) 464-4733 or email me at <br /> m pierce(cr)waterboards.ca.gov. <br /> Marcus Pierce <br /> Associate Engineering Geologist, <br /> Federal Facilities Unit <br />