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Nestl6 USA Inc. • - 6 - • 16 June 2005 10. Page 17, Section 5.4: The conclusions summarized in this section miss the primary reason for assessing VOC trends. The focus of trend analysis should be on those areas that have significant increasing trends because these areas may require actions such as increasing the sampling frequency, installing additional monitoringlextraction wells, and/or improving hydraulic containment to prevent spread of the VOCs plume and protect sensitive receptors. This section provides general conclusions on plume stability and natural attenuation rather than identifying the potential areas where Nestl6 may need to focus their attention and resources. Revise this section. 11. Page 17, Section 6: Providing conclusions that restate general observations on groundwater elevations and plume stability that have been provided in previous annual reports is redundant and deflects attention from the important issues/concems. Nestle should limit this section to problems or potential concerns identified in the previous sections and provide recommend actions to address them. The section should include all concerns and recommended actions in this comment letter. All existing conclusions should be deleted except for bullet#8. 12. Page 18, Section 6: Recommended reductions in sampling frequencies in bullet#8 will not be approved without submission of Nestle's decision logic for well sampling frequencies for our review/concurrence. Assuming this happens,monitoring wells M-21C1 and M-21D should be removed from the list of wells proposed for reduction because nearby municipal well MW-11 resumed operation in 2004. 13. Page 18, Section 7: Add an implementation schedule to complete all 2005 activities, including those requested in this letter. A draft implementation schedule should be submitted to Regional Board staff for review/concurrence before being added to the Final Annual Report. Future Draft Annual Reports should also include a proposed implementation schedule for all activities planned during that reporting period. 14. Page 18, Sections 7.1 and 7.2: This section should include all 2005 reporting and field actions recommended in this letter and Section 6. 15. Table 2: Flag all of the groundwater elevation data that is considered anomalous or was not used in preparing the groundwater potentiometric surface maps (Figures 3,4, and 5). 16. Table 4: This table does not provide the vinyl chloride results for effluent samples. Add them to the table. Also, add a footnote explaining where mid-point samples are collected and provide total gallons treated and average gallons per minute in 2004 for each well. 17. Table 5: Municipal wells MW-5 and MW-11 resumed operation in 2004, so add production data for them. Add footnotes indicating why municipal wells MW-9 and MW-12 were not operational in the second half of 2004. 18. Table 6: The summary of vertical gradients in this table is very confusing. Nestl6 needs to reorganize the wells into Upper-Intermediate Aquifer well pairs and Intermediate-Lower Aquifer well pairs. If needed, Regional Board staff can provide examples of ways to improve presentation of this data(see General Comment 4).