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CALIFORNIA REGIO*WATER QUALITY CONTROL BOARD• Cal/EPA - CENTRAL VALLEY REGION 9 3443 RorAier R6ad, Suite A (�',AN Puq,rtyo�eU Sacramento, CA 95827-3098 Phone(916)255-3000 ��W; FAX(916)255-3015 Pete Wilson,Governor 19 September 1997 Mr. Verrill Norwood Pioneer Chlor Alkali Company, Inc. 116 Sunburst Lane, NW Cleveland, TN 37312 FIRE POND 2: FIELD INVESTIGATION AND CLOSURE WORK PLAN, ALL PURE CHEMICAL COMPANY, TRACY, SAN JOAQ UIN CO UNTY I have reviewed the 26 June 1997 report entitled Fire Pond 2: Field Investigation and Closure Work Plan submitted by Helmick & Lerner (HL) for the All Pure Chemical Company facility in Tracy. The report describes sampling activities and results associated with closure of Fire Pond 2 at the All Pure facility. The report partially completes the reporting required in my 18 October 1996 letter. That letter required All Pure to report the soil sampling results of the former small wastewater pond and the two wastewater ponds at the same time as reporting the sampling results of Fire Pond 2. The continued discharge of process water to the two wastewater ponds has delayed soil sampling in these two ponds. However, All Pure should have sampled soil in the former small wastewater pond. The following discussion is relative to the soil sampling conducted in Fire Pond 2. Soluble Concentrations of General Minerals and Volatile Organic Compounds (VOCs) All Pure collected discrete soil and soil vapor samples from Fire Pond 2. Soil samples were collected from the sidewalls and floor of the pond, and one soil vapor sample was collected from the floor of the pond. One soil sample from the floor of the pond was analyzed for general minerals by the waste extraction test using deionized water (DI WET), and soluble VOCs by the toxicity characteristic leaching procedure (TCLP)using deionized water. Four sidewall samples were analyzed for soluble VOCs by TCLP using deionized water. All Pure concludes that soluble minerals and VOCs in soil beneath the Fire Pond 2 do not present a potential threat to ground water quality. All Pure bases this conclusion on a comparison of soluble concentrations of VOCs to primary maximum contaminant levels (MCLs) and soluble concentrations of inorganics to primary and secondary MCLs and to water quality in local water supply wells. All Pure's evaluation of the potential impact of soluble inorganics and VOCs in soil to ground water has not considered applicable water quality goals which may be less than MCLs and has not considered dilution of the extracted soluble soil sample or the attenuation available in the soil column. Even considering these other factors, it does not appear that soluble inorganics or VOCs are a threat to ground water quality. Recycled Paper Our mission is to preserve and enhance the quality of California's water resources,and ensure their proper allocation and efficient use for the benefit of present and future generations.