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i ENVIRONMENT& <br /> RUSTINFRASTRUCTURE <br /> RUST Environment&Infnmucnae Inc. <br /> 6143 South Willow Drive,Suite 200 <br /> Enr)ewood,C0 80111-5123 <br /> Tel.(303)694-6660•FAX(303)694-4410 <br /> August 28, 1994 <br /> Mr. Victor Izzo <br /> California Regional Water Quality Control Board <br /> Central Valley Region <br /> 3443 Routier Road, Suite A <br /> Sacramento, California 95827-3098 <br /> Re: Response to Comments on Final Remedial Investigation Report - <br /> Nestle Beverage Company Facility, Ripon, California <br /> RUST E&I Project No; 88853.000 <br /> Dear Mr. Izzo: <br /> On behalf of Nestle Beverage Company, RUST Environment&Infrastructure (RUST E&I) has <br /> reviewed the comments prepared by the Regional Water Quality Control Board (RWQCB) <br /> dated August 9, 1994 on the Final Remedial Investigation (RI) Report, and has prepared the <br /> following response. In general, we believe that the comments can be addressed by pointing <br /> out existing information that has been presented in previous submittals to the RWQCB, or by <br /> clarifying the language used in the document. Th-t ...)Ilowing paragraphs address each of the <br /> RWQCB's comments. <br /> Comment I: Section. 4.1, Ground Water, Paragraph 2; The report states, "Non- <br /> detections in production wells, however, were considered in defining the <br /> extent of impacts in all units. " This appears inappropriate. Many <br /> production wells cover several ground water units and nondetect in a <br /> well may represent dilution rather than no contamination in any of those <br /> units. In general production wells should not be used'in. plume <br /> definition. <br /> Response: The language in question was taken from a document submitted to the <br /> RWQCB in February 1991, the Phase VI report. Please note that the <br /> sentence states that non-detections were considered in defining the extent <br /> of impacts. Nestle is well aware that the local production wells are <br /> completed across several zones, and for that reason has never used the <br /> production well data as a firm basis for depicting concentration contours. <br /> Comment 11: Section. 4.2.2, Soil Gas Sampling Results, Paragraph 1; The report <br /> states, "Although the industrial sewer located along Industrial Avenue <br /> and Fourth Street has been considered as a possible explanation for <br /> elevated TCE in this area, samples taken from the sewer and wells near <br /> the sewer in 1992 indicate that the sewer is not a potential source. " This <br /> statement does not appear to be supported by the data. Monitoring well <br /> Quality through teamwork C1 <br />