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California Regional Water Quality Control Board <br /> Central Valley Region <br /> Robert Schneider,Chair Arnold <br /> Alan C.Lloyd,Ph.D. <br /> Agency Secretary Sacramento Main Office Schwarcenegger <br /> 11020 Sun Center Drive#200,Rancho Cordova,California 95670-6114 Governor <br /> Phone(916)464-3291 •FAX(916)464.4645 <br /> http://www.waterbouds.ca.gov/cmtmlvalley <br /> 22 February 2005 RECDPMDD <br /> 4 2no5 <br /> Mr. Michael Desso ENVIRONMENT HEALTH <br /> Nestle USA, Inc. PERMIT/SERVICES <br /> 800 North Brand Boulevard <br /> Glendale, California 91203 <br /> DRAFT WORK PLAN FOR INITIAL TESTING AND CHARACTERIZATION PROGRAM, <br /> FORMER NESTLE USA-BEVERAGE DIVISION, INC. FACILITY, RIPON, SANJOAQUIN <br /> COUNTY <br /> Thank you for the opportunity to review the Draft Work Plan for Initial Testing and Characterization <br /> (Draft Work Plan) received on 11 November 2004. Regional Board staff comments on the Draft Work <br /> Plan are provided below. <br /> General Comments <br /> 1, The Draft Work Plan suggests the proposed investigation will provide data to be used for design of <br /> a final bioremediation program. Regional Board staff does not believe the 1-month push-pull tests <br /> will provide sufficient data to support long-term application of in situ carbohydrate-enhanced <br /> bioremediation. The testing proposed in the Draft Work Plan should be used to support a 6-to 12- <br /> month pilot study that will provide sufficient time to induce reducing conditions in the test area and <br /> 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 <br /> testing will be used to design a longer pilot test that will be detailed in a future work plan. <br /> Alternatively,Nestl6 may propose a more rigorous and longer-term pilot study in lieu of the 1- <br /> month push-pull tests. <br /> 2. Regional Board staff is not aware of any successful bioremediation programs in the Central Valley <br /> where molasses was utilized as the primary substrate. The Draft Work Plan should cite and briefly <br /> discuss bioremediation pilot studies in our region or similar hydrogeologic environments involving <br /> injection of molasses. The Draft Work Plan should also discuss the advantages/disadvantages of <br /> using molasses as a substrate instead of other potential amendments like HRC, lactic acid, com <br /> syrup,..etc. If there aren't any successful pilot studies using molasses either in our region or at sites <br /> with similar hydrogeology to Ripon,we recommend using a substrate with a more proven <br /> performance record. <br /> California Environmental Protection Agency <br /> p�a Recycled Paper <br />