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Mr. Mike Desso • - 3 - • 15 September 2008 <br /> Nestle USA Inc. <br /> Concentrations of COCs have been reported in the domestic well depicted on <br /> Figures 9, 10, and 11 of the Annual Report on the north side of Mid Canal'Road`, <br /> approximately 1,630 feet southeast of monitoring well M-38C and 1,170 feet=Souttiwesf <br /> of monitoring well M-32C. The domestic well is screened within the Intermediate Aquifer <br /> and the concentration of TCE on 8 May 2008 was 10 µg/L. Therefore, it is reasonable to <br /> assume that the 0.5, 5.0, and 10 µg/L TCE concentration contours on Figure 9 extend <br /> from the wastewater ponds, across the river, and beyond the domestic well. Nestle <br /> should include the 8 May data on the figure and redraw the concentration contours <br /> accordingly. <br /> The concentration of cis-1,2-DCE on 8 May 2008 was 23 µg/L in the domestic well. <br /> Therefore, it is reasonable to assume that the 0.5, 5, and 10 µg/L cis-1,2-DCE <br /> concentration contours on Figure 10 extend from the wastewater ponds, across the river, <br /> and beyond the domestic well. Nestle should include the 8 May data on the figure and <br /> redraw the concentration contours accordingly. <br /> The concentration of vinyl chloride on 8 May 2008 was 5.4 µg/l- in the domestic well. <br /> Therefore, it is reasonable to assume that the 0.5 µg/l- vinyl chloride concentration <br /> contour on Figure 11 extends from the wastewater ponds, across the river, and beyond <br /> the domestic well. (The 5 µg/L contour was not included on the figure.) Nestle should <br /> include the 8 May data on the figure and redraw the concentration contour accordingly. <br /> Nestle should record the presence or absence of water in City and Neenah Paper <br /> Company (Neenah) ponds during quarterly monitoring events. Also, Nestle should <br /> obtain data on the time and duration that water was present in each pond throughout <br /> each quarter. In addition, Nestle should indicate which of the ponds were dry on the <br /> groundwater surface contour maps presented in the Annual Report. This may allow <br /> Nestle to understand the nature of COC transport in groundwater within the Upper and <br /> Intermediate Aquifers away from the ponds. These data should be included in future <br /> annual reports. <br /> 4. City Municipal Well MW-9. As you know, in April 2003 Nestle entered into an agreement <br /> with the City. One of the conditions of the agreement was that the City would maintain <br /> pumping (with carbon filtration) of water from municipal well MW-9, screened within the <br /> Intermediate Aquifer. The City has pumped, on average, approximately 420 gallons per <br /> minute from MW-9 since the agreement was initiated. <br /> Concentrations of the COCs TCE and cis-1,2-DCE in municipal well MW-9 appear to <br /> have declined somewhat over the last decade. However, over two periods each lasting <br /> seven months during which time the well was not operated, concentrations of both <br /> CDCs rebounded somewhat. The first period lasted from September 1997 through <br /> March 1998, and the second period from July 2004 through January 2005. While the <br /> pumping of MW-9 appears to have resulted in declining concentrations of CDCs in the <br /> Intermediate Aquifer, Nestle cannot show the effect it has had on the piezometric <br /> surface, and as a result, the area of COC capture. Nestle should install a sufficient <br /> number of monitoring wells near MW-9 to evaluate the effect that pumping has on the <br /> plume migration. <br />