SITE INFORMATION AND CORRESPONDENCE

Home Browse Search

FAX:(916)255-3015 � aum 9 May 1996 Mr. Verrill Norwood Pioneer Chlor Alkali Company, Inc. 116 Sunburst Lane, NW Cleveland, TN 373171 CLOSURE PLAN, ALL PURE CHEMICAL COMPANY, TRACY, SAN JOA QUIN COUNTY I have reviewed the 22 June 1994 Closure Plan submitted for the All Pure Chemical Company (All Pure) facility in Tracy. The report was submitted when All Pure expected to have its wastewater recycling system operational by 1 July 1994 and the three wastewater ponds closed by 1 January 1995. All Pure's wastewater recycling system did not go through initial test runs until late March 1996. Mr. Vickers, the current plant manager of the All Pure facility, has informed me that he expects the recycling system to be fully operational around the middle of May 1996. The closure plan does not address all the concerns associated with closure of the ponds for a number of reasons. Most importantly, the analyses to be performed on soil samples from beneath the ponds should include volatile organic compounds (VOCs), general minerals, pH, electrical conductivity, and total dissolved solids (TDS). These are the main constituents of concern with respect to potential impact to ground water quality. In addition, soil samples should be collected from the sides, as well as from the bottom of each pond, and from the areas surrounding the ponds to determine the lateral extent of soil contamination. Samples should be collected at a minimum of five-foot intervals, and at significant changes in lithology, from the ground surface to the water table. Soil gas samples also should be collected for VOCs, since VOCs are frequently most prevalent in vapor phase in soil. The closure plan must include a proposal for closure of all ponds to be closed and a map identifying all ponds. Mr. Vickers has informed me that the pond currently containing water for fire protection, the pond which used to receive water containing iron residuals, and the pond which receives water containing water softener are also going to be closed. All Pure may be required to file a report of waste discharge to continue using these ponds if they will not be closed at the same time as the ponds which now receive wastewater. We would then issue waste discharge requirements for these remaining ponds. One of the wastewater ponds proposed for closure in 1994 appears to have already been closed. This is the small lined pond immediately northwest of MW-2. The closure plan must include information on the closure of this pond, including the date of closure, the results of any soil sampling from beneath the pond, the fill material used, and any grading done. The closure plan must propose the necessary sampling if the soil beneath this pond was not sampled before closure.