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Nestle USA, Inc., Ripon, California March 31, 2011 <br /> 2010 Annual Report <br /> 2. justification for screening out certain remediation technologies from further evaluation in <br /> the vicinity of the City of Ripon waste water treatment plant (WWTP). <br /> The 2011 Revised FS report, submitted to the RWQCB on January 28, 2011, addressed these <br /> requests as follows: <br /> • ECM prepared a detailed description and evaluation of previous remediation <br /> technologies and remedial approaches tested or applied at the Site. This information is <br /> presented in Appendix A of the 2011 Revised FS report. <br /> • AMEC prepared a focused feasibility analysis of: <br /> o in-situ air sparging (IAS; biosparging), <br /> o bioaugmentation, and <br /> o groundwater recirculation with ex-situ treatment. <br /> • AMEC provided additional justification for retaining intrinsic remediation (IR) as an <br /> appropriate treatment of the dissolved phase COCs by analyzing geochemical indicator <br /> parameters in groundwater samples from select monitoring wells during the Second and <br /> Third Quarter monitoring events. AMEC used the results to document the occurrence <br /> and rate of IR occurring at areas of VOC impacts across the Study Area. The analysis is <br /> included in the 2011 Revised FS as Appendix B. The details of this study will be used to <br /> develop an IR program for the Study Area as a final remedy. <br /> • ECM used the Groundwater Model to validate the updated remedial alternatives <br /> proposed in the 2011 Revised FS report. <br /> 2.6 WATER MANAGEMENT PLAN FOR THE RIPON STUDY AREA <br /> Nestle prepared the Water Management Plan for the Ripon Study Area (WMP) for water users, <br /> providers, and regulators (stakeholders) to address issues related to water quality and water <br /> resources within the Study Area. The goals of the WMP are: <br /> 1. Maintain and protect groundwater quality in the Study Area; <br /> 2. Identify predominant factors that influence groundwater quality; <br /> 3. Identify processes that can help maintain or improve groundwater quality; and <br /> 4. Implement these processes through cooperation among key stakeholders. <br /> Nestle has already established the framework for implementation the WMP with the completion <br /> of work in several key areas including: <br /> 1. Completion of a summary of key stakeholders who have a direct impact on water quality <br /> as part of the WMP; <br /> 2. Implementation of a comprehensive monitoring program; <br /> 3. Development of a WRCP to provide replacement water to affected users, as necessary; <br /> 4. Completion of additional work on a comprehensive well inventory for the Study Area. <br /> Additional historical data sources were investigated in 2010. <br /> 5. Focused group activity by select stakeholders to address water quality issues such as <br /> local management of total dissolved solids (TDS). <br /> 6. Development of "buffer zones" between the COC plume in each aquifer and future well <br /> placement through the use of the Groundwater Model. The buffer zones identify areas <br /> 5 <br />