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S1TATE Usti CALIFORNIA-Environmental Protectimency PETE WILSON Governor c�ALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD CENTRAL VALLEY REGION ENVIRONMENTAL HEALTH 3443 Routler Road,Suite A PERMIT SERVICE Sacramento,CA 95827-3098 PHONE:(916)255.3000 FAX:(916)255-3052 34 NOV 30 PH 1: 27 t� . . . 28 November 1994 Mr. Frank Zumstein Nestles Beverage Company 230 Industrial Ave. Ripon, CA 95366 WATER QUALITYASSESSMENT, NESTLES BEVERAGE COMPANY, RIPON, SAN JOAQUIN COUNTY We have reviewed the Water Quality Assessment, Nestles Beverage Company,received 31 August 1994. We concur with the cleanup goals established in Table 6.3, Calculated Concentrations in Soil and Vapor Based on Measured Ground Water Quality Goals. Our major concern in this report is that an assumption is made that the lateral and vertical extent of vadose zone contamination is defined. However, based on the data presented in this report and the Remedial Investigation (RI), it appears that the vadose zone lateral and vertical extent of contamination is not defined. Vadose zone interim remediation should continue both on and offsite, with definition of the lateral and vertical extent of vadose zone contamination being included in pre-design investigation of the final remedy. The following are specific comments on the report: I. Section 1.0 - Introduction The report states, "The site has been fully characterized and a final Remedial Investigation (RI) report was submitted to the RWQCB on February 1, 1994." We do not concur with this statement as stated above. Three source areas has been identified,but the lateral and vertical extent of contamination has not been completed. We agree though that this further definition work can be included in the pre-design work. 11 Section 6.0- Recommendations for Soil Source Area Remediation a. Paragraph 2 This paragraph discusses soil remediation verification by drilling one boring every 2500 feet . This spacing may be appropriate for certain areas,but a greater density may be appropriate near the source area. More discussion is needed on how locations will be selected. Sampling is needed both near the center of the source area as well as along the perimeter. b. Paragraph 4 The report states, "The sample(s) from each boring will be analyzed using California WET procedures for volatile organic compounds." Because of the significant under reporting, in many cases, of volatile organic compounds by traditional soil sampling, compound specific soil gas sampling is also required to verify cleanup. A soil gas sampling plan will have to be developed.