ARCHIVED REPORTS_2011 REVISED FEASABILITY STUDY

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Nestle USA, Inc.—Ripon, CA January 28, 2011 2011 Revised Feasibility Study alternatives which involve the discharge of treated ground water to surface water, such as the River or local irrigation district. The National Ambient Air Quality Standards (NAAQS) and the National Emission Standards for Hazardous Air Pollutants (NESHAPS), 40 CFR, Parts 50 and 61, establish the Federal regulations for ambient air. Similarly, California requirements under Regulation IX"""v" incorporate NESHAPS ambient air limits. These action-specific requirements may pertain to the Study Area, if a remedy that is selected such as air stripping could emit regulated chemicals. Further, the San Joaquin Valley Unified Air Pollution Control District Rule 2201 requires a permit for any air or vapor discharge, which would apply to operation of air stripper or soil vapor extraction system. Other federal action-specific requirements which could apply to particular remedial actions include the Underground Injection Control Program, which provides for protection of ground water during injection of fluids in injection wells or trenches. This could pertain to the Study Area if reinjection of treated ground water is chosen as a treated water disposal option. Other State of California action-specific requirements which could apply, depending on the selected treated water disposal action, include Water Well Standards for any new well construction as part of a selected remediation. Federal RCRA and state hazardous waste requirements do not pertain to treated ground water under Section 261.4 of RCRA and Section 66261.4 of the California State requirements. However, RCRA and the state hazardous waste requirements could apply to any sludge and treatment residuals generated during groundwater treatment, if the waste is a mixture of a listed waste, or exhibits any characteristic of a hazardous waste as described in Section 261.3 of CFR and Section 66261.3 of the State of California requirements. 7.3 Location-Specific Requirements State Water Resources Control Board Resolution No. 92-49 describes policies and procedures to address sites where wastes have been discharged so as to cause or threaten to cause pollution of waters of the state. The Policy requires dischargers to clean up groundwater and soils which threaten to pollute groundwater to the extent that beneficial uses of that water resource are restored and protected. This policy was revised in 1996, to include provisions to address sites where compliance with water quality objectives for groundwater cannot reasonably be achieved within a reasonable period of time. The Site is not located within a flood plain area""'. No applicable location- specific requirements apply. 8 General Response Actions General response actions address the RAOs described in Section 5 for groundwater. Except groundwater, no other medium in the Study Area requires action. These actions relate to basic methods of protection such as treatment or 21