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California Regional Water Quality Control Board . ``�° ' � <br /> Central Valley Region ,� <br /> Robert Schneider Chair <br /> Alan C.Lloyd Ph.D. Arnold Schwarzenegger <br /> Secretary for Sacramento Main Office Governor <br /> Environmental Internet Address: http://www.waterboards.ca.gov/centralvalley <br /> Protection 11020 Sun Center Drive#200 Rancho Cordova,CA 95670-6114 <br /> Phone(916)464-3291 Fax(916)464-4797 <br /> r 4 E-.DD <br /> 20 May 2005 <br /> mg 2 3 ?005 <br /> Mr. Sam ChamberlainRpq�MM1 HEF`l�H <br /> Pioneer Americas LLC P�RMIT �RNC�t, <br /> 700 Louisiana Street, Suite 4300 <br /> Houston, TX 77002 <br /> REVIEW OF REPORTS, PIONEER AMERICAS LLC (FORMERLY ALL-PURE <br /> CHEMICAL COMPANY), 26700 SOUTH BANTA ROAD, TRACY, SAN JOAQUIN.COUNTY <br /> Staff of the Central Valley Regional Water Quality Control Board (Regional Board)reviewed the <br /> 2 November 2004 2004 Semi-Annual Groundwater Monitoring and Sampling Report(Semi- <br /> Annual Report) and the 4 May 2005 2004 Annual and First Semi-Annual 2005 Monitoring and <br /> Sampling Report(Annual Report) submitted by SECOR International Incorporated on behalf of <br /> Pioneer Americas LLC for the facility at 26700 South Banta Road in Tracy(site). The Semi- <br /> Annual Report summarizes the groundwater monitoring activities conducted in May and August <br /> 2004 and recommends monitored natural attenuation(NINA). The Annual Report summarizes <br /> the groundwater monitoring activities conducted in November 2004 and February 2005, <br /> evaluates the reductive dehalogenation of carbon tetrachloride as part of the MNA sampling, <br /> proposes to submit a Cleanup Plan by 31 May 2007, and recommends a revised monitoring and <br /> reporting program(MRP). <br /> Regional Board staff have the following comments on the Annual Report: <br /> 1. Some of the data provided in the Appendix C of the Annual Report shows qualified data <br /> and samples analyzed outside of EPA recommended holding times. Pioneer must include <br /> a quality assurance/quality control check of the data to evaluate the validity of the data. <br /> 2. Regional Board staff does not concur with the recommendations for the revised MRP <br /> because it does not adequately monitor site pollutants and does not include MNA <br /> monitoring. Therefore, attached is a revised draft MRP,which incorporates MNA <br /> monitoring. <br /> 3. Groundwater elevation data south of the irrigation canal in the Upper Horizon appears to <br /> have several anomalies. Pioneer needs to explain these anomalies. Furthermore, Pioneer <br /> should obtain well survey information for the monitoring wells associated with the <br /> Defense Distribution Depot San Joaquin County California Tracy site (DDJC) for the <br /> Upper and Middle Horizon along Banta Road to further evaluate groundwater gradient <br /> and direction. <br /> California Environmental Protection Agency <br /> C"Recycled Paper <br />