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t 0 0 <br /> California Regional Water Quality Control Board <br /> Central Valley Region ' <br /> Robert Schneider,Chair <br /> Alan C.Lloyd,Ph.D. Arnold <br /> Agency Secretary Sacramento Main Office Schwarzenegger <br /> 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor <br /> Phone(916) terb a,•FAX(916)4644645alley ECE#VED <br /> hop://www.waterboards.ca.gov/centralvalley (I'1� IIV�. <br /> 28 June 2005 JUL <br /> 8 ?005 <br /> ENVIRONMENT HEALTH <br /> Mr. Michael Desso PERMIT/SERVICES <br /> Nestl6 USA, Inc. <br /> 800 North Brand Boulevard <br /> Glendale, California 91203 <br /> RESPONSE TO COMMENTS ON WORKPLAN FOR INITIAL TESTING AND <br /> CHARACTERIZATIONPROGRAM, FORMER NESTLE USA,INC. FACILITY, RIPON, SAN <br /> JOAQUIN COUNTY <br /> Central Valley Regional Water Quality Control Board staff(Regional Board staff) has reviewed Nestle <br /> USA Inc.' responses to Regional Board staff comments on the Draft Work Plan for Initial Testing and <br /> Characterization Program (RTCs) received on 2 May 2005. With the exception of the few responses <br /> discussed below, most of the responses are sufficient to address Regional Board staff concerns. <br /> General Comment 1 <br /> The Draft Work Plan suggests the proposed investigation will provide data to be used for design of a <br /> final bioremediation program. Regional Board staff does not believe the 1-month push-pull tests will <br /> provide sufficient data to support long-term application of in situ carbohydrate-enhanced bioremediation. <br /> The testing proposed in the Draft Work Plan should be used to support a 6- to 12-month pilot study of <br /> enhanced bioremediation that will provide sufficient time to induce reducing conditions in the test area <br /> and fully assess potential adverse impacts to groundwater. Nestl6 should either revise the Draft Work <br /> Plan to include a second and longer phase of pilot testing or to state the results of the proposed testing <br /> will be used to design a longer pilot test that will be detailed in a future work plan. Alternatively, Nestle <br /> may propose a more rigorous and longer-term pilot study in lieu of the 1-month push-pull tests. <br /> Nestle Response: The intent of the initial testing and characterization proposed is to gather data to <br /> enable design of a pilot-scale remediation system focused on groundwater where target constituents <br /> appear to primarily occur, within the Upper Aquifer. Consistent with this intent, theplanned treatment <br /> zone will cover aground area of approximately 500 feet by 500 feet. Once the pilot-scale remediation <br /> system is in-place, the performance will be monitored and evaluated and modification will be made as <br /> necessary. Information obtained f om the pilot-scale system will be used to determine if the system is <br /> appropriate without modif cation, if modifications need to be made to optimize performance or to design <br /> alfdury and potentially more r civ system as aDDYOprlate <br /> California Environmental Protection Agency <br /> 64%Recycled Paver <br />