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WASTE DISCHARGE REQUIREWTS ORDER NO.99-09 • -3- NESTLE USA-BEVERAGE DIVISION INC. RIPON FACILITY SAN JOAQUIN COUNTY 12. The Discharger proposes to provide control measures for constituents in the pilot test zone which includes pumping from at least one existing groundwater extraction well (EW-1)that will provide hydraulic containment of groundwater in the pilot test area starting 4 months after potassium permanganate has been applied to the treatment zone. To assure that chemical oxidation of TCE can occur, pumping must cease for 4 months to allow for adequate distribution of the potassium permanganate. A hydraulic capture zone analyses was conducted by the Discharger to determine how far the potassium permanganate and its by-products and any untreated TCE would migrate if pumping would cease for 4 months. These analyses suggest that the potassium permanganate by- products and untreated TCE would not migrate outside of the capture zone of the extraction well during this time period. 13. Any release of potassium permanganate into the groundwater is a discharge of waste as defined by the California Water Code. These WDRs authorize the Discharger to inject potassium permanganate into groundwater according to all the conditions of this permit. However,the discharge of potassium permanganate is intended to provide more efficient remediation of TCE contaminated groundwater and may significantly reduce the anticipated cleanup time of the aquifer if only pump and treat were used to remediate the groundwater. Cleanup times using pump and treat exclusively to remediate the entire aquifer to concentrations below the detection limit of 0.5 µg/1 TCE is estimated at 125 years. 14. The Discharger proposes to inject up to 8600 gallons of 15 g/I potassium permanganate into the A , aquifer zone at five locations extending from 90 to 120 feet below the ground surface. The injection locations are approximately 80 feet from extraction well EW-1. Extraction well EW-1 will pump groundwater at a rate ranging from 20 to 60 gpm, starting four months after injection of potassium permanganate occurs. Groundwater gradient data indicate that the injection zone is upgradient and that the potassium permanganate will move in the direction of extraction well EW-1. 15. The Water Quality Control Plan for the Sacramento River Basin and San Joaquin River Basin, Fourth Edition, identifies the beneficial uses of the groundwater for domestic, municipal, industrial and agricultural supply. 16. The beneficial uses for the Stanislaus River are municipal, industrial and agricultural supply, groundwater recharge, recreation, aesthetic enjoyment, and the preservation and enhancement of fish,wildlife and other aquatic resources. 17. The permitted discharge is consistent with the antidegradation provisions of State Water Resources Control Board Resolution No. 68-16 (Anti-degradation Policy). The discharge may result in some exceedance of background but is consistent with the maximum benefit to the people of the State. 18. Issuance of this Order is exempt from the provisions of the California Environmental Quality Act (Public Resources Code, Section 21000, et seq.), in accordance with Section 15308, Title 14, California Code of Regulations. 19. The Board has notified the Discharger and interested agencies and persons of its intent to prescribe waste discharge requirements for this discharge and has provided them with an opportunity for a public hearing and an opportunity to submit their written comments and recommendations.