SITE INFORMATION AND CORRESPONDENCE

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California Reg nal Water Quality C Strol Board Central Valley Region Robert Schneider,Chair Gray Davis Winston H.Hickox Governor Secretary for Sacramento Main Office Environmental Internet Address: http://www.swrcb.ca.gov/rwgcb5 Protection 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Phone(916)255-3000•FAX(916)255-3015 11 May 2001 Ms. Lisa Tuck Pioneer Companies, Inc. 700 Louisiana Street, Suite 4300 Houston, TX 77002 REVIEW OF INVESTIGATION AND ANNUAL MONITORING REPORTS, PIONEER AMERICAS, INC. (FORMERLY ALL-PURE CHEMICAL COMPANY), TRACY, SAN JOAQUIN COUNTY We have reviewed the 27 April 2001 2000 Annual Report and First Semi-Annual 2001 Groundwater Monitoring and Sampling Report(Monitoring Report) and the 30 April 2001 Submittal of Groundwater Investigation Report(Investigation Report) submitted by SECOR International Incorporated (SECOR) on behalf of Pioneer Americas Incorporated (Pioneer) for the facility located at 26700 South Banta Road, Tracy(site). The Monitoring Report discusses the sampling conducted during November 2000 and February 2001 and summarizes the monitoring results and activities at the site for 2000. The Investigation Report documents the results of three cone penetrometer test (CPT) locations collected during November 2000 along with the data obtained from 12 CPT locations performed in November 1999 and analytical results obtained from five reports submitted by Montgomery Watson on behalf of the U.S. Department of Defense Distribution Depot San Joaquin, Tracy Facility(DDJC-Tracy). One grab groundwater sample was collected from each of the three horizons (upper/above upper, middle and lower) for each of the 15 CPT locations Carbon tetrachloride and chloroform are not delineated east of CPT location AP-CPT 08 in the upper/above upper or middle horizons. Chloroform is not delineated east of CPT location AP- CPT 10 in any of the three horizons. The CPT locations delineate a majority of the extent of carbon tetrachloride and chloroform in the three horizons,but monitoring wells are needed to monitor the plumes on a continual basis. By 15 June 2001, please provide a work plan to install additional monitoring wells to evaluate groundwater flow trends north of the site and to provide consistent lateral and vertical definition of carbon tetrachloride and chloroform in groundwater. Also by that date, submit an evaluation of remedial alternatives prepared in general accordance with the attached Items To Be Included In California Environmental Protection Agency �a 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