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0 0 <br /> California Regional Water Quality Control Board - <br /> Central Valley Region <br /> Robert Schneider,Chair <br /> Alan C.Lloyd,Ph.D. Arnold <br /> Agency Secretary Sacramento Main Office 1,1 1. 07 Schwarzenegger <br /> 11020 Sun Center Drive#2O0,Rancho Cordova,California 9587/6@114,. Governor <br /> Phone(916)464-3291 •FAX(916)464-4645 tEF4;d1""'PEPoTANTY <br /> http://www.waterbouds.ca.gov/mntralvalley FiEALTFi DEP.E TMENT <br /> AL <br /> 28 September 2005 <br /> Peter Weiler and Steven Michaelson <br /> Environmental Risk Services Corporation <br /> 2121 N. California Blvd., Suite 820 <br /> Walnut Creek, CA 94596 <br /> GROUNDWATER INVESTIGATION WORKPLAN, BULK TERMINALS SITE,PORT OF <br /> STOCKTON, SAN JOA QUIN COUNTY <br /> We have reviewed the Response to Comments, Groundwater Investigation Work Plan, Bulk Terminals <br /> Site, Port of Stockton. The following outlines our final comments: <br /> 1. Location of C-7 and C-8: We understand that ERS does not recommend drilling within the coal <br /> piles. The borings shall be advanced in an area that adequately characterizes the soil and <br /> groundwater beneath the coal stockpile. <br /> 2. Soil and Groundwater Analytical Methods: We concur with the approach of utilizing the citrate <br /> extract if the pH is at or below 6 and the USEPA analytical methods. <br /> 3. Soil and Groundwater Analysis: Regional Board does not concur with the proposed reduction of <br /> the soil and groundwater analysis. The purpose of this initial groundwater monitoring event is <br /> for the characterization of the soil and groundwater beneath the site. Under low pH conditions, <br /> metals have the ability to become more mobile, thereby potentially increasing the plume size and <br /> direction. In addition, it is important that all of the wells be analyzed for the same constituents so <br /> that the wells can be compared with each other and with background. <br /> Therefore, the soil and groundwater samples collected as described in the sampling plan shall be <br /> analyzed for: bicarbonate, calcium, magnesium, sulfate, sodium, nitrate, chloride, sulfur, title 22 <br /> metals, pH, TDS, alkalinity, EC, THE, BTEX and PAHs. <br /> Upon completion of the initial round of sampling, further monitoring, if warranted, may be <br /> significantly reduced. <br /> California Environmental Protection Agency <br /> Qa Recycled Paper <br />