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California Regional Water Quality Control Boards . Central Valley Region Robert Schneider,Chair ;Gray Davis Winston H.Hickox -�'"° Governor Secretaryfor Sacramento Main Office ,c Environmental Internet Address: http://www,swrcb.ca.gov/rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 c 14 Phone(916)255-3000•FAX(916)255-3015 9 May 2002 _ ', T Ms. Lisa Tuck Pioneer Companies, Inc. 700 Louisiana Street, Suite 4300 Houston, TX 77002 REVIEW OF MONITORING REPORTS, PIONEER AMERICAS LLC (FORMERLY ALL- PURE CHEMICAL COMPANY), TRACY, SAN JOAQUIN COUNTY We have reviewed the 23 October 2001 Second Semi-Annual 2001 Groundwater Monitoring and Sampling Report (QMR) and the 26 April 2002 2001 Annual Report and First Semi-Annual 2002 Groundwater Monitoring and Sampling Report(Annual Report) submitted by SECOR International Incorporated on behalf of Pioneer Americas LLC (Pioneer) for the facility at 26700 South Banta Road in Tracy. The QMR discusses the groundwater monitoring activities conducted in May and August 2001. The Annual Report discusses the groundwater monitoring activities conducted in November 2001 and February 2002, results of the private well survey and sampling, and status of access agreements to install monitoring wells on adjacent properties. We have the following comments on these reports: 1. The QMR does not discuss the results of the May or August 2001 sampling events. Although the Annual Report provides a thorough discussion of the analytical and groundwater elevation results, each monitoring report must include a discussion of the results in comparison to historical data. 2. The Annual Report discusses the concentrations of carbon tetrachloride and chloroform in the "Pombo"private well but does not discuss the detection of carbon tetrachloride in the upgradient "Skaggs"private well. Pioneer must discuss all detections of constituents of concern in private wells. 3. Water quality objectives (WQOs) listed in the Fourth Edition of the Water Quality Control Plan for the Sacramento River and San Joaquin River Basins include numeric WQOs, such as state drinking water maximum contaminant levels that are incorporated by reference, and narrative WQOs such as the toxicity objective and taste and odor objective. The narrative toxicity WQO for carbon tetrachloride is implemented by the numerical limit of 0.1 micrograms per liter(µg/1), which is the California Public Health Goal for Drinking Water. EPA analytical method 8260B has a reporting limit of 0.5 µg/1,which is higher than the WQO. Based on low concentrations of carbon tetrachloride and a majority of the monitoring wells being reported as non-detect at the higher reporting limit, Pioneer must use an analytical method that will detect carbon tetrachloride at or below the WQO. Drinking water analytical methods, such as the 500 Series, can achieve a lower reporting limit. California Environmental Protection Agency 0 Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5