Laserfiche WebLink
]ENVIRONMENTAL COST MANAGEMENT,INC. <br /> Managing Cost and Liability <br /> 3525 Hyland Avenue,Suite 200 <br /> Costa Mesa,California 92626 <br /> Main:(714)662-2759 Fax:1714)662-2758 <br /> March 20, 2015 <br /> Marcus Pierce, P.G., C. Hg <br /> Associate Engineering Geologist <br /> California Regional Water Quality Control Board-Central Valley Region <br /> 11020 Sun Center Drive, #200 <br /> Rancho Cordova, CA 95670 <br /> Re: RESPONSE TO COMMENTS ONDRAFT REMEDIAL ACTIONPLAN, FORMER <br /> NESTLE USA,INC. FACILITY, RIPON,SAN JOA Q UIN CO UNTY <br /> Dear Mr. Pierce: <br /> On behalf of Nestle USA, Inc., Environmental Cost Management, Inc. and Haley and Aldrich <br /> respond to Regional Water Quality Control Board comments on the Draft Remedial Action Plan <br /> dated February 5, 2015. <br /> Nestle's response to comments prepared by ARCADIS on behalf of Ron and Karen Fisher(e- <br /> mailed from RWQCB to Nestl6 on January 30, 2015) is included as Attachment A to this letter. <br /> General Comments <br /> 1. The comments on the Draft RAP in this letter will require significant revisions to the <br /> document. Therefore, Nestle should submit the next version of this document as a draft <br /> or revised draft. <br /> Nestle Response: Comment noted. Based on discussions during a conference call between <br /> Regional Water Quality Control Board(Water Board)personnel and Nestle representatives on <br /> 12 February 2015,Nestle understands that the Water Board does not expect Nestle to submit a <br /> revised final RAP in 2015. The submittal date will be determined at a later time. <br /> 2. Much of the proposed groundwater remedy in the Draft RAP relies on monitored natural <br /> attenuation (MNA) to restore local groundwater. Although the Draft RAP does not <br /> explicitly state MNA is an approved remedy for the site, it appears to be implied. In past <br /> discussions with Nestle and comments on the Feasibility Study, Central Valley Water <br /> Board staff has indicated we cannot accept MNA as a remedy component without further <br /> evidence it can restore local groundwater in a reasonable timeframe. One additional <br /> remedial objective that we have not discussed in detail is Nestl6 also needs to demonstrate <br /> MNA will be protective of human health and groundwater quality. <br />