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Port of Stockton - 2 - 27 May 2014 Rough and Ready Island Stockton, San Joaquin County to describe the outcome of the investigation (for example, based on the analytical results presented in Table X, further site investigation was conducted in [date]). 3. For soil analytical data tables, please provide a column showing from which transects the soil samples came (for ease of locating the soil samples on the maps). For groundwater data, since IAS-09 wells are actually located in adjacent sites, please add a column to the groundwater tables referencing the site location. It is very difficult to locate the various samples/wells on the figures, and the record must be made clear. 4. For figures, please make sure the title block identifies the site. Figures 3 and 10 are appropriately labelled, the others are not. 5. Please ensure that all groundwater data from the various groundwater zones are properly placed on the correct figure. For example, several figures only contained data from the shallow water-bearing zone, but were labelled as deep-water-bearing zones. ERS did provide corrected copies upon my request for this review. These new figures need to be added to future reports. 6. In reviewing the report, the soil analytical data became confusing regarding the units and analysis being used. For example, Table 6 and Table 7 state the units are in mg/kg and values exceeding baseline are highlighted in red. Yet, the tables contain sample data labelled WET with a comparison to a soil baseline, not the DI WET baseline. Also, the units are in mg/kg not ug/L (if a WET test had been performed). Table 7 is labelled slightly more clearly. 7. Ensure the notes at the end of the tables are referencing the correct baseline. Table 9 references a WET baseline for groundwater samples, when the reference should read groundwater baseline. Specific Comments: Central Valley Water Board staff does not concur with the ERS conclusion that the soil and groundwater analytical data presented in the Report are sufficient to characterize the environmental conditions and potential risks to human health and ecological receptors at the site. The following concerns are listed below: 1. Data gaps regarding groundwater impacts exist at IAS-09, mainly in the northern section of the site. POS will be required to conduct additional site assessment of soil and groundwater impacts in the areas along IAS-09 where these data gaps occur. Once these data gaps have been investigated, additional studies in the form of Remedial Investigation/Feasibility Studies may be required. Central Valley Water Board staff wishes to be very clear that construction of a UPRR rail line shall not inhibit any future soil or groundwater investigation. We will require, as necessary, POS to perform soil and groundwater sampling and/or groundwater monitoring within the UPRR easement. 2. Central Valley Water Board staff request groundwater sampling and submittal of groundwater monitoring reports for site IAS-09 be conducted semi-annually until further