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California Regional Water Quality Control Board ' Central Valley Region ., Steven T.Butler,Chair Gray Davis Winston H.Hickox Secretary for Sacramento Main Office Governor 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 6 S 17 November 2000 Ms. Lisa Tuck Pioneer Companies, Inc. 700 Louisiana Street, Suite 4300 Houston, Texas 77002 MONITORING AND REPORTING PROGRAM, PIONEER AMERICAS, INC. (FORMERLYALL- PURE CHEMICAL COMPANY), TRACY, SAN JOA Q UIN CO UNTY Enclosed is a copy of Monitoring and Reporting Program No. 5-00-846 (MRP) for the Pioneer Americas, Inc. (Pioneer; former All-Pure Chemical Company) Tracy facility. We have incorporated IT Corporation's (IT) 22 September 2000 comments on the draft MRP except as follows: • IT requested that the term"Discharger"be substituted throughout with "Pioneer". Pioneer(or its predecessors)polluted shallow groundwater beneath the site and, therefore, is considered a Discharger. We did not change the MRP based on this comment. • IT requested that the second column of the table of constituents (titled Maximum Reporting Limit) be titled either"Maximum Detection Limit" or"Minimum Reporting Limit". The Maximum Reporting Limit column, as stated in the footnote, is the maximum limit for nondetectable results (i.e., the reporting limit shall be 0.5 µg/1 or lower). Therefore, we did not revise the column heading. Additionally, Pioneer may report the results as "nondetect" or"below the reporting limit" and list the reporting limit in another column, or may report results with a less than symbol. • IT requested that subparagraph(a) on page 2 of the MRP be revised to include semiannual sampling events. Since the MRP requires quarterly sampling events but only semiannual reporting, we did not modify the MRP. • IT requested that we modify the MRP so the mass of contaminants removed would not need to be calculated in the semiannual reports. The requirement concerns ongoing remediation(e.g., soil vapor and groundwater extraction). If Pioneer starts a remediation system while this MRP is in effect, these data will be required. Additionally,while we have not required mass removal rates for past excavation projects, we may require estimates of contaminants removed for future excavation projects and total mass removed if ultimately considering this site for closure. The annual report is required to describe all remediation activities conducted for the year. If none were conducted, then the annual report needs to include a comment stating such. California Environmental Protection Agency �a� Recycled Paper