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Nestle USAInc. • - 4 - 16 June 2005 Examples of monitoring frequency decision flowcharts were provided to Nestle's previous consultant several years ago, but a project-specific one was not developed from these examples. Regional Board staff can't concur with monitoring reductions until Nestle provides a monitoring frequency decision diagram or flowchart for our review/concurrence. 10. The stability of the plume should be carefully assessed in each annual report. Regional Board staff request that Nestle add three new figures showing a comparison of the plume extent for the reporting year and the previous four years for the Upper, Intermediate, and Lower Aquifer zones. Regional Board staff can provide examples of these figures submitted for other TCE plumes in the Central Valley. 11. There are recommended actions in our comments on previous Annual Reports that have not been completed yet. Please review the previous comment letters issued in 2000 through 2004 and tabulate all requested actions that have not been completed and provide an explanation why. This can be a separate submittal from the Final Annual Report for 2004, but should be attached to your response to comments in this letter. 12. The Draft Annual Report references a recent USGS article by Burow (2004) that contains information on the local hydrostratigraphy. Please provide a copy of this article with the Final Annual Report 13. Please provide a copy of the Final Annual Report for 2004 and future Annual Reports to Ms. Sonya Harrigfeld of Stanislaus County Department of Environmental Resources. Specific Comments 1. Page 1, Section 1.1: There are references to the"source areas"in subsequent section so the Draft Annual Report, so identify the known source areas in this section. 2. Page 1, Section 1.2: The B-aquifer zone overlies the A-aquifer zone, so switch the order of"A" and "B" in the second sentence of the first paragraph. 3. Page 7, Section 2.2: The maximum contaminant level(MCL)is not an effluent limitation for cis- 1,2-DCE or an acceptable performance standard for the Nestle's TPs, so delete ", however,the concentration remained below MCL in the discharged water." 4. Page 10, Section 4.1.1: Explain the apparent groundwater mound in the vicinity of monitoring well clusters M-3 and M-22 in 1Q04 and 4Q04. Groundwater elevation data collected from well TH-9 is interpreted as anomalous in all 4 quarters in 2004 because the elevations at this well are consistently lower than Upper Aquifer wells to the north. In response to a request from Regional Board staff in 2003, monitoring well data from Ripon's monitoring network near the municipal wastewater ponds was incorporated into Nestle's monitoring program in 1Q05 and suggests there is westward flow(parallel to the river) in the Upper Aquifer near the municipal ponds. This new data indicates the 2004 data collected from TH-9 is not