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All Pure Chemical Inspection Rert i -2-' The plant manufactures bleach between June and the end of September. During that time the two onsite supply wells pump about 40,000 gallons of water per day. Information provided by All Pure staff shows these wells are completed to depths of 90 and 200 feet below ground surface (bgs). Mr. Vickers loaned me videotapes of these two wells. From my review of these tapes, the wells appear to be completed to 99 and 242 feet bgs. The 99 foot well appears to be screened from about 65 to 97 feet bgs. The 242 foot well appears to be screened from about 50 to 68 feet, from 91 to 138 feet, and from 159 to 240 feet bgs. Mr. Norwood insisted the carbon tetrachloride in ground water beneath All Pure was not from the All Pure facility and suggested it may have originated from the pipeline along the Southern Pacific Rail Road to the northeast of All Pure. As Mr. Norwood stated, all ground water elevation measurements at All Pure have shown that the shallow ground water flows to the southwest, from the area of the ponds towards the two production wells. This is in contrast to the northeast ground water flow direction shown by DDRW during its remedial investigation. I showed Mr. Norwood the analytical results of Board staff sampling of the Ponds 1 and 2 in January 1988 which showed carbon tetrachloride was present in both ponds, at concentrations of 7.5 ppb and 4.3 ppb, respectively. Mr. Norwood stated he was not aware of these data. Mr. Norwood stated that carbon tetrachloride may have been present in All Pure's chlorine in the past, since it was used in the drying train for chlorine until about 1988. When I requested to sample water in the wastewater ponds, Mr. Norwood stated that the water in the ponds was only rainwater. We collected samples from each of Ponds 1, 2, 3, and 4 and the two onsite supply wells. During sampling, we noted the plastic liners in Ponds 1 and 2 were torn in many places along the edges and bottoms of the ponds. Pond 3 had no liner, and the liner in Pond 4 was in fair condition. Ponds 1 and 2 were each very full, with almost no freeboard in Pond 1 and less than one foot of freeboard in Pond 2. All Pure reported that Ponds 1 and 2 are approximately four feet deep. The presence of water between Pond 1 and a nearby ditch indicated Pond 1 had recently overflowed offsite to the east. Any overflows from the ponds would discharge to the offsite ditch and potentially to the fields directly northeast of the facility (see attached map). An anonymous complaint received on 12 September 1995 informed Board staff that these ponds regularly overflowed during the winter of 1995. The attached analytical results from our laboratory are summarized below and show that chloroform, carbon tetrachloride, and other volatile organic compounds (VOCs) were present in Ponds 1 and 2 in January 1996. Chloroform and other VOCs were also present in Ponds 3 and 4. Sample Pond 1 NW was taken from the northwest corner of Pond 1, Pond 1 NE was taken from the northeast corner of Pond 1, Pond2 SE was taken from the southeast corner of Pond 2, Pond2 S was taken from the south end of Pond 2. Our chemist also noted that each pond sample was caustic, with a pH of at least 10. Constituent Pond 1 NW Pond 1 NE Pond2 SE Pond2 S Pond 3 Pond 4 (ue/1) Wgd) (�� (k-1 i Wl Carbon Tetrachloride 65.4 60.7 30.6 23.4 <1.2 <1.5 Chloroform 406 438 237 189 2.7 8.1 Bromodichloromethane 29.4 35.0 27.0 20.9 <1.2 8.8 Dibromochloromethane 6.1 6.9 4.3 3.0 <1.2 11.8 Bromoform <1.5 <1.2 <1.5 <1.5 <1.2 13.3 Chlorobenzene <1.5 <1.2 <1.5 <1.5 8.6 <1.5 Napthalene 12.0 10.8 6.4 7.2 trace 8.0 2-Chlorotoluene <1.5 <1.2 <1.5 <1.5 2.6 <1.5