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0F CALIFORNIA REGIOAWATER QUALITY CONTROL BOARD Cal/EPA CENTRAL VALLEY REGION v 3443 Routier Road, Suite A Sacramento, CA 95827-3098 Phone(916) 255-3000 „� FAX(916) 255-3015 J Pete Wilson,Governor 26 August 1997 Mr. Verrill Norwood Pioneer Americas, Inc. 116 Sunburst Lane, N.W. Cleveland, TN 37312 GROUND WATER INVESTIGATION REPORT, ALL PURE CHEMICAL COMPANY, TRACY, SAN JOAQUIN COUNTY I have reviewed the 1 August 1997 report entitled Ground Water Investigation Report (GWIR) submitted by Helmick & Lerner for the All Pure facility in Tracy. The report discusses the installation of two monitoring wells, MW-7 and MW-8, and the drilling of one deep boring, DB-1, on the All Pure facility. Two additional monitoring wells are proposed which we discussed during our 19 August 1997 meeting. My comments on the report follow. Laboratory Analyses The chain of custody forms are missing from the laboratory results. All Pure must submit these forms. Storage of Drill Cuttings and Purge Water Drill cuttings, development water, and purge water were stored in drums at the site for subsequent disposal. All Pure proposes to dispose of these properly based on the results of laboratory analyses. All Pure must submit all appropriate laboratory analyses and obtain Board approval before disposing any of these wastes onsite. Recommendations for Additional Monitoring Wells All Pure proposes to install two more monitoring wells, one offsite in the shallow zone and one onsite in the deep zone. This is in contrast to the two shallow monitoring wells proposed in the 13 January 1997 work plan to be installed offsite. All Pure proposes to eliminate one of the originally proposed offsite monitoring wells based on the recent determination of a north to northeasterly ground water flow direction, as opposed to the southwesterly flow direction previously measured. The proposed offsite monitoring well will determine the extent of volatile organic compounds (VOCs) downgradient of the two wastewater ponds. The second offsite monitoring well originally proposed in the January work plan would determine the extent of VOCs downgradient of hydropunch location HP-5, where elevated concentrations of VOC in ground water were detected. As discussed during our meeting, All Pure must determine the lateral extent of VOCs downgradient of HP-5 either by insitu ground water sampling or a by installing a monitoring well. The onsite deep well is proposed to be installed upgradient of the two wastewater ponds, since All Pure states that mobilizing a drill rig in the area downgradient of the ponds would be impractical. Installing the deep monitoring well upgradient of the wastewater ponds will not yield useful information regarding the potential impact of VOCs on the deeper aquifer. As we discussed during our meeting, All Pure should install the deep monitoring well downgradient of the wastewater ponds. It would be appropriate to install this well adjacent to the proposed offsite shallow monitoring well which is downgradient of the two wastewater ponds. Recycled Paper Our mission is to preserve and enhance the quality of California's water resources,and I-ArIx ensure their proper allocation and efficient use for the benefit of present and future generations.