ARCHIVED REPORTS_2011 REVISED FEASABILITY STUDY

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Nestle USA, Inc.—Ripon, CA January 28, 2011 2011 Revised Feasibility Study 1 . Introduction Nestle USA, Inc. ("Nestle") retained Environmental Cost Management, Inc. (ECM) to prepare this 2011 Revised Feasibility Study ("Revised FS") report for the remediation of impacted groundwater related to a facility ("Site") Nestle once operated in Ripon, California (Figure 1). For the purpose of this report, the term "Site" refers to the property on which Nestle historically operated at 230 Industrial Avenue in Ripon, CA. The term "Study Area" refers to a larger area of investigation of approximately four square miles in the Ripon vicinity, as depicted on Figure 2. A comprehensive Visual Executive Summary is included in this 2011 Revised Feasibility report (see above). The California Regional Water Quality Control Board (RWQCB) Central Valley Region issued Cleanup and Abatement Order R5-2006-0720 (CAO) on July 24, 2006. The CAO permits revision of the Feasibility Study (FS) that Nestle submitted in 1994'. 1.1 Purpose of Report This 2011 Revised FS report expands analysis of Study Area remedial options as recommended by the RWQCB. It follows the sequential feasibility study process recommended by the United States Environmental Protection Agency (USEPA) and documents the following: • Important past site activities including site background and history, • Factors considered during the development of the feasibility study, • Determination of Remedial Action Objectives (RAOs), • Determination of General Response Actions, • An identification and analysis of the various remediation technologies, • The assembly of technologies to form remediation alternatives, and • The evaluation of remediation alternatives based upon specific criteria. The feasibility study process yielded a remediation alternative. The authors of this 2011 Revised FS strived for consistency with the goals stated by the RWQCB and attempted to present a document that will be suitable for further development into a Remedial Action Plan (RAP). This Revised FS builds upon earlier work, including an FS prepared in 1994, an addendum to the 1994 FS submitted to the RWQCB in February 1998, and another revision dated October 1998. Those earlier works are summarized below. • The 1994 FS recommended pump-and-treat for cleanup of the known extent of the trichloroethene (TCE) plume at the time. However, Nestle understood at that time that pump-and-treat may require indefinite operation to bring the Site to closure. Groundwater modeling was 1