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14 <br /> California Regional Water Quality cloontrol Board F <br /> Peter M. Rooney Central Valley Region Ed J. Schnabel <br /> Secretaryfor Chair <br /> Environmental Sacramento Main Office <br /> Protection Internet Address: http://www.swreb.ca.gov/--rwgcb5/home.html <br /> 3443 Routier Road,Suite A,Sacramento,California 95827-3003 <br /> Phone(916)255-3000•FAX(916)255-3015 <br /> 16 December 1998 <br /> Mr. Andrew A. Woods <br /> Kemwater North America <br /> 2185 N. California Blvd., Suite 500 <br /> Walnut Creek, California 94596 <br /> MODIFIED CLOSURE PLAN FOR PONDS I AND 2, ALL PURE CHEMICAL COMPANY, <br /> TRACY, SAN JOA QUIN COUNTY <br /> I have reviewed the 20 November 1998 Modified Closure Plan for Ponds 1 and 2, All Pure <br /> Chemical Company, Tracy, submitted by International Technology Corporation (IT Corp.) for <br /> Pioneer Companies, Inc., parent company of All Pure Chemical (APC) Company. The proposed <br /> modifications to the Ponds 1 and 2 closure plan is in response to my 23 October 1998 review of <br /> the closure plan. I have the following comments. <br /> 1. My 23 October 1998 letter raised the issue that the soluble concentrations of chloride, <br /> sodium, total dissolved solids and electrical conductivity in Ponds 1 and 2 soil samples are <br /> much greater than previous ponds closed at the site. I requested modification of the Ponds 1 <br /> and 2 closure plan to provide specific recommendations for removing the contaminated soil, <br /> taking confirmation samples, and treating or disposing of the excavated soils. I approve the <br /> proposal in the Modified Closure Plan for Ponds 1 and 2 to take additional soil samples at <br /> four location(two in each pond) and analyze them for total and soluble sodium and chloride. <br /> 2. The Modified Closure Plan for Ponds I and 2 proposes a soil cleanup goal for both total <br /> sodium and chloride of 2,000 mg/1 using the Board's Designated Level Methodology. These <br /> cleanup goals are based on an assumed groundwater quality goal of 200 mg/l for both sodium <br /> and chloride and a combined attenuation and leachability factor of 10. The work plan does <br /> not provide specific information on the sodium and chloride leachability or attenuation <br /> characteristics of the soils beneath Ponds 1 and 2 to justify this combined attenuation and <br /> leachability factor. <br /> Generally, sodium and chloride are considered highly soluble constituents. Chloride has a low <br /> potential for adsorption and is often considered a conservative tracer, i.e. does not readily <br /> adsorb. Therefore, a chloride leachability and adsorption factor of one is appropriate for the <br /> soils beneath Ponds 1 and 2. <br /> California Environmental Protection Agency <br /> C4 Recycled Paper <br />