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Nestle USA hic. • - 3 - 28 June 2005 Nestle hotspot. Nestle should assess baseline concentrations of metals and monitor for a full suite of metals during push-pull tests and the longer-term pilot test-recommended in General Comment 1. Nestle Response: We are not aware of metals, other than antimony and arsenic, which would potentially be of concern as a result of the proposed tests. We request that additional rationale for the request of metals other than antimony and arsenic. Although Regional Board staff does not have any data from pilot studies specifically involving injection of molasses in our region, it has been our experience at other in situ treatment sites that some metals can be mobilized. Nestle has not provided data from tests conducted at similar sites outside the Central Valley. As such, Nestle needs to explain hydrochemically why there are only two metals that can potentially be mobilized and provide monitoring data from previous tests that demonstrate other metals will not be mobilized before we can concur with limiting metals monitoring to arsenic and antimony. If this information is not provided, then Nestle will have to include monitoring for a full suite of metals in the Final Work Plan before Regional Board staff can concur with its implementation. Specific Comment 3 Table 1: Some of the proposed analyte reporting limits in this table are too high. For example, the proposed reporting limits (RLs) for cVOCs are 1 to 2 orders of magnitude higher than the RLs that Nestle achieves under the existing long term groundwater monitoring program. Revise the RL for cVOCs to 0.5 µg/L and the RL for sulfate to 1 mg/L. Also, add a full suite of metals to this table with RLs equal to or less than the lowest applicable water quality objectives or the lowest RLs that can be achieved with EPA analytical methods. Nestle Response: We will revise the target reporting limits to equal those achieved during the long-term groundwater monitoring program. However, we request additional rationale for your request to add a full suite of metals to the analytical program. Chloroform will be added to the analyte list. A revised Table 1 is attached. See General Comment 9 above for our response on requesting rationale for analyzing for a full suite of metals. The proposed reporting limit(100 µg/L) for arsenic and antimony in Table 1 is approximately 2 to 3 orders of magnitude above applicable water quality objectives. Nestle needs to achieve the reporting limits for metals provided in Table 1 of the new Monitoring and Reporting Program that will be issued later this month. Additional Comments on the Draft Work Plan: 1. Regional Board staff request that Nestle analyze influent and effluent samples at the Industrial Avenue treatment system for both VOCs and TDS on a weekly basis during the one-month push-pull tests. Samples should be analyzed on 24-hour turnaround and should be immediately reported to Regional Board staff. Add these new conditions to the Final Work Plan. 1. The Cs indieate=Nestle-will-monitor-DS-during-the-push-pull-test-and-the-volum"f-water discharged to the treatment plant will be adjusted or stopped if concentrations of TDS are higher than