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Port does not agree that there is an urgent need,nor in fact any need for further investigation of <br /> IAS-09 in this area. <br /> The second required action is as follows:"Please submit a proposal for semi-annual groundwater <br /> monitoring and reporting at site IAS-09. POS has not been conducting groundwater monitoring <br /> on a regular basis. To evaluate the need for additional site assessment and/or remedial action at <br /> site IAS-09, groundwater monitoring is necessary. POS has the option of providing this proposal <br /> on a voluntary basis, or if it is helpful, Central Valley Water Board staff can provide POS with a <br /> Monitoring and Reporting Program Order(MRP)." <br /> The Port has not conducted regular ground water monitoring at IAS-09 because the lack of <br /> ground water impacts due to releases of OCPs at IAS-09 has already been adequately <br /> documented.There have never been any detections of OCPs in ground water at IAS-09, and this <br /> includes four quarters or more of sampling with no detections of OCPs in the wells located in the <br /> portion of the site where dissolved OCPs would be most likely to occur. Thus the demand for <br /> semi-annual monitoring is unjustified, as there is no plume to monitor. <br /> In conclusion,the comments received from the CVRWQCB in the letter dated 27 May 2014 do not <br /> provide any technical or logical justification for the additional work that is being requested. The <br /> Port cannot undertake any further site assessment at IAS-09 without specific guidance from the <br /> CVRWQCB as to why the data already produced for IAS-09 are inadequate. <br /> Page 4 of 4 e 1 s <br />