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Nestle USA, Inc., Ripon, California March 31, 2011 <br /> 2010 Annual Report <br /> 2.2 GROUNDWATER INVESTIGATION <br /> In September 2010, ECM conducted a CPT investigation in the vicinity of well M-1 OA to assess <br /> the causes of recent increases in concentrations of COCs. ECM completed subsurface <br /> lithology and groundwater investigation activities at 14 CPT boring location S4. Investigation <br /> details and action taken can be found in Section 3.1.6. <br /> Based on the evaluation of the 2010 data and historical information for M-10A, ECM <br /> recommended commencing groundwater extraction from well EI-1 at the Site. On October 29, <br /> field personnel optimized well EI-1 to run at 90 gallons per minute (gpm) concurrently with wells <br /> EU-3 and EU-4, both running at 31 gpm. Since these three wells are all completed in the Upper <br /> Aquifer, the total groundwater extraction rate of 152 gpm applies to the A-zone of the Upper <br /> Aquifer. Wells EI-1, EU-3 and EU-4 have continued to operate at these rates since October 29, <br /> 2010. Section 4.1.1 provides additional information regarding the start-up of EI-1. <br /> 2.3 GROUNDWATER MONITORING <br /> Nestle completed the following activities in 2010 as part of the groundwater monitoring efforts: <br /> 1. ECM submitted the 2009 Annual Reports to the RWQCB on March 31, 2010 pursuant to <br /> the MRP requirements. <br /> 2. ECM submitted the First, Second and Third Quarter Site Status reports to the RWQCB <br /> on May 14, August 13, and November 15, 2010 respectively, as required by the MRP. <br /> 3. In 2010, ECM's field staff conducted a quarterly inspection of the physical condition of all <br /> Nestle-owned monitoring wells to ensure that the well casings are locked and in good <br /> condition. Some wells required attention. The corrective actions are further discussed <br /> in Section 3.1.6. <br /> 4. On May 1, 2010, Nestle implemented monitoring and sampling in accordance with MRP <br /> R5-2010-0810. <br /> 2.4 INTERIM REMEDIAL ACTION PLAN SYSTEM PERFORMANCE <br /> Remediation of TCE impacted groundwater at the 230 Industrial Avenue location (the On-Site <br /> extraction and treatment system) continues pursuant to the approved IRAP (mass removal and <br /> migration control). The following activities were conducted in 2010: <br /> 1. ECM monitored and assessed the IRAP system performance by monitoring pumping <br /> rates and calculating mass removal rates on a monthly basis, and by evaluating the <br /> hydraulic containment periodically. <br /> 2. On May 4, 2010, ECM initiated a 72-hour shut-down test of the Industrial Avenue <br /> groundwater extraction and treatment system. The purpose of this test was to collect <br /> groundwater elevation data for the existing and new monitoring wells (M-50A and M- <br /> 51A) and to estimate the hydraulic capture zone for extraction wells EU-3 and EU-4. <br /> Section 4.1.2 and Section 5.3 provide details of this test. <br /> 2.5 2011 REVISED FEASIBILITY STUDY <br /> Following the submittal of the 2009 Revised FS report, the RWQCB requested additional <br /> information regarding: <br /> 1. the detailed evaluation of remediation technologies used for all zones impacted by the <br /> presence of COCs onsite and offsite, and <br /> 4 <br />