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,STATE OF CALIFORNIA-Environmental Protection f,-ncy PETE WILSON Govemor CALIFORNIA REGIONAL WATER QUALITY:CQ�I��O� BOARD CENTRAL VALLEY REGION 'ITSERVli' °' A. 3443 Routier Road,Suite A � �� Sacramento,CA 95827-3098 'nn —9 ply 12: PHONE:(916)255-3000 FAX:(916)255-3015 6 August 1996 Mr. Verrill Norwood Pioneer Chlor Alkali Company, Inc. 116 Sunburst Lane, NW Cleveland, TN 37312 CLOSURE WORK PLAN SURFACE IMPOUNDMENTS, ALL PURE CHEMICAL COMPANY, TRACY, SAN JOAQUIN COUNTY I have reviewed the 24 June 1996 Closure Work Plan submitted by Helmick and Lerner Inc. for the surface impoundments at the All Pure Chemical Company (All Pure) facility in Tracy. Four ponds are proposed to be closed in this work plan. The previous plan, submitted in July 1994, proposed to close only three ponds, two of which are included in the current proposal and one of which has already been closed. The current closure work plan does not address all of the concerns in my 9 May 1996 letter, which commented on the July 1994 closure plan. Most importantly, the work plan does not propose a schedule for closing the ponds, the analytical methods to be performed on the soil samples, or soil gas sampling, and does not include complete details of closure of the small pond in 1994. These and additional concerns are discussed below in reference to the noted sections of the report. BACKGROUND The small impoundment that was backfilled in 1994 is not shown on Figure 1 as stated, nor on Figure 2. Both figures should show the location of this impoundment. The report states that the stormwater collection pond will continue to be operated according to Regional Board requirements. The Board does not currently have requirements on the stormwater pond, as implied. As discussed below under the heading Stormwater Collection Pond, All Pure may be required to have a stormwater permit. Fire Protection Water Impoundments The work plan states that Fire Pond 2 sediments were collected, characterized, and properly disposed. The work plan should provide the method of characterization, any analytical results, and the method of disposal of the sediments.