Laserfiche WebLink
Page 8 <br /> of the proposed well or other actions to assist in review of the new well permit <br /> application. Nestle needs to set-up a similar process with the local agencies and the Draft <br /> WMP should be revised to document it. <br /> In Sacramento County, any permit application within 2,000 feet of a known plume <br /> triggers review by Central Valley Water Board staff. This 2,000-foot buffer is based on <br /> available pumping data and the professional judgment of staff working on the larger <br /> plumes in the County. A similar buffer needs to be determined for Nestle's groundwater <br /> contamination based on the local pumping data and hydrogeology. We request that <br /> Nestle review the available pumping data and propose a buffer that is sufficiently <br /> conservative and protective of human health and water quality. <br /> Nestle Response: This will be discussed with the counties during the upcoming meeting. <br /> 13. Central Valley Water Board staff believes the Draft WMP and Draft Public Participation <br /> Plan should not be joined with the RAP as these documents can be finalized sooner than <br /> the Interim RAP. Furthermore, the WMP should be implemented as soon as possible. <br /> Please remove them from the Interim RAP. <br /> Nestle Response: These will be converted to stand alone documents and finalized after the <br /> meeting with the Counties. <br /> 14. The hard copy of the Draft RAP began to fall apart as soon as it was opened. <br /> Furthermore, this document is difficult to review without separating the text from the <br /> figures and appendices.With the next version of the RAP and all future reports that <br /> contain hundreds of pages (including the 2014 Annual Report due at the end of March <br /> 2015), please use a standard 3-ring binder of adequate size. Thanks. <br /> Nestle Response: Comment noted for future submissions. As for the Draft RAP, enclosed <br /> with this transmittal letter is a larger binder. <br /> Specific Comments <br /> 1. Page 1, Section 1, Introduction: It is unclear which guidance documents Nestle used in <br /> preparing the Draft RAP. Reference them in this section and add them to Section 7. <br /> Nestle Response: This change will be incorporated into the final RAP. <br /> 2. Page 2, Section 3.1,Mass Removal and Containment: Currently,MNA is not approved as <br /> part of the remedy. Revise the first objective from "Hydraulically control and contain <br /> COCs..." to "Hydraulically control and capture COCs exceeding MCLs..." <br /> Nestle Response: This change will be incorporated into the final RAP. <br /> 3. Page 2, Section 3.1.1, Capture Zone Analysis and Pilot Reinjection Test: The last <br /> sentence indicates the proposed groundwater extraction and treatment system"will be <br /> designed to accommodate higher flow rates to account for uncertainty inherent in <br />