ARCHIVED REPORTS_2011 REVISED FEASABILITY STUDY

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2 1 INTRODUCTION On behalf of Nestle USA, Inc. (Nestle), the IT Corporation (IT) conducted a potassium permanganate injection pilot study' in August 1999 at the Industrial Avenue site (the Site). The study was completed at four locations at the Site, targeting three depth intervals within the Upper Aquifer. Potassium permanganate (KMn04) is typically soluble in groundwater and is effective as an oxidizer in remedial applications2. Both soils and groundwater can be treated in-situ with KMn04 without the need for pumping and removing water from the aquifer. However, in less permeable formations, or aquifers which are interbedded with low permeable lenses, adequate distribution of the KMn04 solution presents a significant challenge. Potassium permanganate works through a strong oxidative reaction of chemical bonds associated with many organic compounds, and can oxidize trichloroethylene (TCE) by breaking its double carbon bonds to produce environmentally benign reaction products including chloride and carbon dioxide. 1.1 Background Information IT submitted a Work Plan for Evaluation of Additional Remedial Actions: KMn04 Pilot Study (Pilot Study Work Plan)3 to the California Regional Water Resources Control Board (RWQCB), Central Valley Region in September 1998. With approval from RWQCB, IT performed a permanganate bench scale test and background groundwater and soil sampling in October and November 1998. The Interim Report Summarizing Background Sampling and Bench Scale Test for the KMn04 Pilot Study (Interim Report)4 was submitted to the RWQCB in December 1998. Nestle completed the following activities to prepare for the pilot study: 1) Waste Discharge Permit application — Nestle was issued Waste Discharge Permit (WDP) Order No. 99-079 on June 18, 1999 from the RWQCB. A groundwater monitoring and reporting program was included in the WDP. The requirements included measuring parameters for the oxidation of volatile organic compounds (VOCs), monitoring for adverse effects from permanganate within the pilot study area, and incorporating sentinel wells outside the pilot study area into the program. The WDP also laid out a contingency plan in the event that adverse effects persisted from the permanganate injection. 2) Aquifer Testing — Nestle evaluated permeability changes with a series of rising- and falling-head slug tests. The pre-injection slug tests were conducted on May 15, 1999 and the post-injection slug tests were conducted on December 23, 1999. 3) Installation of on-site monitoring wells — In June 1999, Nestle installed two new on-site monitoring wells (M-25C1 and M-25C2) to monitor for vertical migration. These wells were screened in separate water—bearing zones in the Intermediate aquifer.