SITE INFORMATION AND CORRESPONDENCE

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Wendy L. Cohen • _2_ • 22 January 1996 Chemicals at All Pure are stored in 15 aboveground storage tanks. The storage tanks are inside a containment wall designed to hold the contents of the largest tank plus 15%. Chemicals stored are chlorine, diluted caustic soda, 50% caustic soda, and muriatic acid. Three-foot high containment dikes surround the concrete tank pad which drains to wastewater ponds (see Figure 2). A 0.2-acre stormwater pond adjacent to the wastewater ponds contains runoff. Three storm drains connect to a pipe which runs underneath the berm between wastewater Pond 1 and the stormwater pond, then into the stormwater pond. All Pure has stated there is no connection between the wastewater ponds and the stormwater pond. There are four lined wastewater ponds which receive wastewater from the process and chemical storage areas, a lined stormwater pond, and one lined 150,000 gallon capacity pond (Pond 5 in Fig. 2)used as water storage for fire suppression. Pond 1 has a capacity of 2,000 gallons. Ponds 2 and 3 have a combined capacity of about 123,400 gallons. Pond 4 has a capacity of about 150,000 gallons. The stormwater pond is designed to collect runoff from the asphalt areas, which is then allowed to evaporate. Two deep wells are present on the site for process water production. One is estimated to be 60 feet deep and the other 150 feet deep. All Pure has not submitted well logs or construction details for these wells. Regulatory Oversight Board staff first inspected the All Pure facility in 1985 in response to a complaint that chemicals were being dumped into the ponds. The attached chronology describes the history of the Board's oversight since 1985. Briefly, All Pure has submitted two reports of waste discharge, the first in August 1985 and the second in April 1992. The Board has not issued waste discharge requirements because All Pure delayed its decision on how to manage its wastewater. All Pure has considered retrofitting the ponds and/or installing a recycling system to eliminate the need for the ponds. Between September 1988 and sometime in 1995, All Pure evaluated a recycling system for managing wastewater at its Marysville facility for applicability at its Tracy facility. The latest information we have is verbal notification in December 1995 that a recycling system has been installed and is expected to be operational by the end of January 1996. All Pure has not submitted a closure plan for the ponds. As required by the Board, All Pure installed four monitoring wells in early 1991. These wells have been monitored quarterly for water levels and water quality since then. All Pure has acknowledged the need to identify sources and extent of volatile organic compound (VOC) contamination, but has not yet done so. Hydrogeology There is very little information about the subsurface geology at the All Pure site. For more detail on the hydrogeology in the area, I have reviewed the investigative reports for the TDD and the Lyoth Loading Station. Figure 1 shows the locations of these facilities relative to All Pure.