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Nestle USA Inc. -2 - 16 June 2005 Regional Board staff believes that all other treated groundwater disposal options available to Nestl6, such as reinjection and discharge to the Stanislaus River, will likely require secondary treatment for inorganics. Furthermore,Nestle' needs to install extraction wells east and south of the municipal ponds to contain/remove the higher VOC concentrations near the Stanislaus River and may extract a portion of the City of Ripon' and Fox River Paper's TDS plumes. Regional Board staff request that Nestl6 begin immediately to design an interim treatment system that will allow Nestl6 to discharge all of its treated groundwater, preferably to the City of Ripon's non potable water system,before the end of 2005 and submit a draft design and implementation schedule for the interim treatment system by 26 August 2005. Nestl6 should also submit a Draft Treated Groundwater Disposal Plan by 2 September 2005 that evaluates the available disposal/reuse options and selects several long-term alternatives that can be quickly implemented to facilitate disposal/reuse of any treated groundwater that can't be discharged to the City of Ripon's non-potable water system in the future. 3. Recent Annual Reports have improved as new summary tables and additional discussion/interpretation of the data has been added each year. However,the reports still lack a thorough assessment of the data and often do not provide recommendations to optimize remedial efforts or correct problems. One example of this problem is provided in the current Draft Annual Report which shows breakthrough of VOCs at the Stockton Avenue TP in 4Q05,yet there is no recommendation to correct this problem and the problem was still unabated when Nestl6 issued the Draft Annual Report on 31 March 2005 and the 1Q05 Status Report on 29 April 2005. Except for presentation of the monitoring data showing breakthrough in Table 4 in the Draft Annual Report, the data was not reported to Regional Board staff and is not identified as a problem in the Draft Annual Report. Another example of a potentially serious issue that is overlooked in the Draft Annual Report is the sudden increase of VOCs detected in Lower Aquifer monitoring well M-61). Concentrations of TCE and cis-1,2-DCE have increased one to two orders of magnitude in the past 2 years,but there are no recommendations to increase the monitoring frequency for this well, investigate why VOCs have begun to migrate rapidly from the Intermediate Aquifer to the Lower Aquifer in the vicinity of this well, or install a well with a deeper screen near M-61)to determine how deep the VOCs have migrated. From conversations with Nestl6's consultants,Regional Board staff understand that they know the recent VOC increases in M-6D are a concern,but failing to discuss it in detail and provide recommendations to address it in the Draft Annual Report only delays necessary corrective actions and may allow the plume to spread further in the Lower Aquifer Zone. Unfortunately, problems like this have occurred periodically in the past 5 years and will likely continue to happen unless Nestle' takes a more proactive role in assessing problems with their monitoring/remediation program and in providing solutions quickly. Regional Board staff have good examples of Annual Reports in our files that could provide a sound framework for Nestl6 to follow in the future annual reporting and recommend that Nestle' schedule an appointment to review/copy some of them. 4. The increasing VOC trends in monitoring well M-6D are a serious concern, but no corrective actions are provided in the Draft Annual Report (see General Comment 4). Nestle should add a recommendation to increase the sampling frequency at this well to quarterly and provide detailed recommendations to completely define the extent of this new Lower Aquifer plume in 2005.