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California Regional Water Quality Control Board ,.,. a <br /> Central Valley Region <br /> Robert Schneider,Chair Gray Davis <br /> Winston H.Hickox Governor <br /> Secretaryfor Sacramento Main Office <br /> Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 <br /> Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 9s �111�J � ! .tap lo <br /> 12 October 2001 <br /> l� <br /> � t <br /> Ms. Lisa Tuck <br /> Pioneer Companies, Inc. <br /> 700 Louisiana Street, Suite 4300 <br /> Houston, TX 77002 <br /> REVIEW OF FEASIBILITY STUDYIREMEDIAL OPTIONS EVALUATION REPORT, <br /> PIONEER AMERICAS, INC. (FORMERLY ALL-PURE CHEMICAL COMPANY), <br /> SAN JOAQUIN COUNTY <br /> We have reviewed the 11 September 2001 Feasibility Study/Remedial Option Evaluation Report(FS) <br /> submitted by SECOR International Incorporated on behalf of Pioneer Americas Incorporated(Pioneer) <br /> for the facility at 26700 South Banta Road, Tracy(site). The FS discusses the results of the groundwater <br /> fate and transport model and eight remedial action alternatives. Of these eight,Pioneer evaluated <br /> monitored natural attenuation(NINA), in-situ biodegradation with hydrogen release compound, <br /> groundwater extraction and treatment using submersible pumps, and point of use (POU)treatment as <br /> feasible alternatives. Pioneer has selected MNA as the site's remedial action based on human health <br /> issues, effectiveness, implementability, and cost. <br /> We have the following comments on the FS: <br /> 1. Section 6.1.1 of the FS shows the breakdown products of carbon tetrachloride,which include <br /> chloroform, methylene chloride, chloromethane, and methane. Table 3-2 of the FS does not <br /> include results for chloromethane or methane and shows only eight detections of methylene <br /> chloride, which means contaminant breakdown is occurring very slowly. Pioneer must analyze <br /> for each of the breakdown products and discuss the breakdown time of carbon tetrachloride and <br /> chloroform at the site based on the minimal detections of methylene chloride. <br /> 2. Section 6.2.1 of the FS states there are 13 existing monitoring wells and eight proposed <br /> monitoring wells. Our 12 June 2001 letter approved a work plan to install seven monitoring <br /> wells, and there are eight existing monitoring wells, which is consistent with the figures provided <br /> in the FS. Pioneer must explain the discrepancies between the numbers of monitoring wells and <br /> submit a work plan for additional well installations, if that is the reason for the discrepancy. <br /> 3. Pioneer must discuss how site contaminants such as chloride, electrical conductivity, and total <br /> dissolved solids will attenuate in the environment. <br /> 4. Pioneer proposes POU,which is pumping the groundwater from domestic wells PW-002 and <br /> PW-003 at 25 gallons per minute and cycling the extracted groundwater through liquid phase <br /> activated granular carbon adsorption systems. The FS does not include contaminant <br /> concentrations for these wells,provide a figure to show their locations, or discuss where the <br /> California Environmental Protection Agency <br /> Q?Recycled Paper <br /> The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. <br /> 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 <br />