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Californ>la Regional Water Quality CIRItrol Board , <br /> Central Valley Region � - <br /> Arnold <br /> Linda S.Adams Karl E. Longley,Sc D, P.E.,Chair <br /> S'ecrernnvfnr Schwarzenegger <br /> Gorernor <br /> fj"11-omnen1ol Sacramento Main Office <br /> Protection 11020 Sun Center Drive#200.Rancho Cordova..California 95670-6114 <br /> Phone(9 16)46FAX(9 16)464-4645 <br /> hEcavEn <br /> pp//www.waterboaterboards.ca.gov/centralvallep <br /> FEB 0 6 2007 <br /> 2 February 2007 <br /> F<<NI RONM ENT�HCMS H <br /> Mr. Joe Hofbauer <br /> Manager, Environmental Health and Safety <br /> Pioneer Companies, Inc. <br /> Houston, TX 77002 <br /> GROUNDWATER MONITORING AND REPORTING PROGRAM - PIONEER AMERICAS <br /> LLC, 26700 SOUTH BANTA ROAD, TRACY, SAN JOAQUIN COUNTY <br /> California Regional Water Quality Control Board, Central Valley Region (Regional Water <br /> Board) has reviewed the Pioneer Americas LLC (Pioneer) Request for Modification of <br /> Current Groundwater Monitoring Program (Modification Request), in your letter dated 27 <br /> August 2006 for the chemical manufacturing facility (Facility) at 26700 South Banta Road in <br /> Tracy. Enclosed is the final Monitoring and Reporting Program (MRP), issued draft to <br /> Pioneer on 20 May 2005. In addition, as discussed below, this letter requires Pioneer to <br /> proceed immediately with installation of a wellhead treatment system on the Pombo well. <br /> On 14 August 2006, you and Ms. Eva Hey of Secor International Incorporated (Secor) met <br /> with Regional Water Board staff to discuss the Facility monitoring and cleanup status. <br /> Pioneer submitted the Modification Request after the meeting as a response to the Regional <br /> Water Board review letter, dated 14 June 2006. The request proposes to add the following <br /> wells to the groundwater monitoring program for the Facility: Two Lower Horizon <br /> groundwater monitoring wells located at the adjacent U.S. Department of Defense Logistics <br /> Agency Distribution Depot and a Pioneer Facility water supply well. The Defense Logistics <br /> Agency wells are located approximately 4,000 feet north of the Facility. <br /> The Regional Water Board has incorporated the Pioneer groundwater monitoring <br /> modification requests into the enclosed final MRP. Also, we have addressed comments on <br /> the draft MRP that Pioneer submitted in a letter dated 17 June 2005. <br /> Background <br /> On 11 September 2001 , Pioneer submitted a report entitled Feasibility Study/Remedial <br /> Options Evaluation Report (Feasibility Study) to the Regional Water Board, which was <br /> approved in a letter dated 12 October 2001 . Pioneer addressed the comments in a letter <br /> dated 7 November 2001. The Feasibility Study discussed results of a groundwater fate and <br /> transport model and presented remedial action alternatives. Pioneer proposed natural <br /> attenuation (MNA) with wellhead treatment of the Reed and Pombo private water supply <br /> California Environmental Protection Agency <br /> (0Recpcled Paper <br />