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Mr. Joe Hofbauer <br /> • - 3 - • 2 February 2007 <br /> Pioneer Americas LLC <br /> supply, the well's horizontal and vertical location should be surveyed, the well should <br /> be configured in a way that groundwater samples can be collected utilizing standard <br /> monitoring well sampling methods, and the well casing should be configured so that <br /> depth to the groundwater surface can be measured. The Regional Water Board <br /> requests Pioneer to submit a letter to the Regional Water Board documenting these <br /> procedures. If these procedures are not practical or possible, Pioneer must install a <br /> monitoring well on the Facility property and screen it within the Lower Horizon. <br /> 3. At least one Lower Horizon monitor well is necessary at a location between Defense <br /> Logistics Agency wells LM177B and LM151B, and water supply well AP-2. A suitable <br /> well location may be available next to a railroad track access road, approximately 40 <br /> to 60 feet northeast of the track's intersection with Banta Road. This location should <br /> be an adequate alternative to locations within the agricultural properties north of the <br /> Facility. <br /> 4. In July 2005, Pioneer installed two additional water supply wells at the Facility: Banta <br /> #1 and Banta #2. These wells were installed to replace water supply wells AP-1 and <br /> AP-2, installed in 1975. The Well Completion Reports, prepared by Calwater Drilling <br /> Co., Inc., are included in Appendix D of the Draft Cleanup Plan. According to these <br /> reports, the soil boring for Banta #1 was 10 inches in diameter and drilled to a depth <br /> of 280 feet bgs. The soil boring for Banta #2 was also 10 inches in diameter, but <br /> drilled to only 200 feet bgs. Both wells were constructed of 8 inch diameter plastic <br /> casing, screened from 90 to 130 feet bgs, and "8X16 gravel" filter packs from 70 to <br /> 130 feet bgs. The Well Completion Reports do not indicate how each boring was <br /> completed below 130 feet bgs. Pioneer should submit a letter or revised well <br /> completion reports that describe how the borings were completed below 130 feet. <br /> Also, please provide specifications for the filter pack. <br /> 5. The Regional Water Board has included groundwater sampling of Facility water <br /> supply wells AP-1, Banta #1 , and Banta #2 in the MRP. Also, monthly compilation of <br /> gallons pumped from each of these three wells has been included in the MRP. In <br /> addition, we have added the four private domestic water supply wells currently <br /> sampled by Pioneer to the MRP. <br /> Additional Comments <br /> 6. The Draft Cleanup Plan should not be finalized until the extent of the COC plume in <br /> the Lower Horizon has been characterized. <br /> 7. As of early 2005, water from the Pombo private water supply well is again being used. <br /> In lieu of wellhead treatment, Pioneer is supplying the Pombo residence with drinking <br /> water through a private contractor. As specified in the Feasibility Study, Pioneer must <br /> begin wellhead treatment of the Pombo well as soon as possible. <br />