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. MEMORANDUM • CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD • CENTRAL VALLEY REGION 3443 Routier Road, Suite A Phone: (916) 255-3000 Sacramento, CA 95827-3098 CALNET: 8-494-3000 4-G TO: Wendy L. Cohen FROM: Philip S. Isorena Senior Engineer Associate Engineer DATE: 1 December 1994 SIGNATURE: CHUM/ V SUBJECT: PHASE 77 POLLUTION ASSESSMENT REPORT, STOC%TON TERMINALS TECHNICAL COMMITTEE, PORT OF STOCKTON, SAN JOAQUIN COUNTY I have reviewed EMCON's 19 September 1994 Phase II Pollution Assessment Report and its 13 and 14 October 1994 letters for the Stockton Terminals Technical Committee (STTC). My comments are presented below. Phase II Pollution Assessment Report 1. Page v, Executive Summary Report: Observations and soils data indicate other potential sources of soil and ground water impact may exist south of the STTC. Comment: Learner Lease is an unlikely contributor to the STTC contamination because it is downgradient of the STTC facilities. Nonetheless, it should be inspected because of the observed soil stainings from auto parts. Also, EMCON and I should get a copy of the preliminary endangerment assessment report. Stockton Petroleum is a potential source in the northwest section of the terminal. Site investigation reports must be obtained from the San Joaquin County Public Health Services (PHS) and reviewed. 2. Page v, Executive Summary Report: Available information was insufficient to determine migration potential outside the STTC facilities. The following additional information is needed to allow determination of sites outside the STTC lease areas for potential as a source of the STTC contamination: Santa Fe Pacific Pipelines (SFPP) test results; Port of Stockton (POS) utilities and pipeline locations, abandonment of pipelines, and disposition of two pipelines used to transfer jet fuel; and a POS production well installed in 1992. Comment: EMCON should request from SFPP, POS, or PHS the missing information to allow determination of other potential sources to the contaminant plume. 3. Page 1-4, Item 1.3.2, Task 4, Assessment of Adjacent Properties Report: The shallow soil sampling program conducted as part of the Interim Pollution Assessment Report (IPAR) investigation detected soil affected by total petroleum hydrocarbons as diesel (TPHd) at locations beyond STTC operations. A limited site assessment was proposed to evaluate potential sources and past land uses.