SITE INFORMATION AND CORRESPONDENCE

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Mr. Alexander Krygsman -2_ 29 January 1992 Stockton, California (19 March 1990) and Proposed Work Plan, Piezometer Installation, Arco Terminal, Stork Drive and Washington Street, Stockton, California (22 May 1990). What is the status of the onsite investigation at ARCO or at any other TC member site which is conducting work outside of the committee? 5. Site Assessment Work Plan Implementation and Schedule. We are also in receipt of the TC' s letter to the port regarding finalization of the TC' s contract among its members. We understand the contract was needed before Emcon Associates could proceed with the site assessment work. The contract is scheduled to be signed by the TC members in mid- February. However, it has been more than two years since the work plan was submitted. Thus, its implementation is long overdue. A time schedule for work plan implementation must be submitted. We request thatyou submit a report by 14 February 1992 which addresses the above items. Furthermore, since the Port of Stockton has allowed fuel products to spill into the soils and ground water underlying its fuel terminal at the port, thereby degrading the ground water quality and impairing the beneficial uses of the state's waters, Board staff sent you on 18 January 1989 a draft Cleanup and Abatement Order which would require the Port of Stockton and six of its tenants at the fuel terminal to: "Cleanup and Abate, forthwith, the effects of petroleum products discharged to soils and ground water at this location". As you well know, staff has not recommended the C&A to give the Port and the TC a chance to assess and remediate the site without an enforcement action from the Board. As we have stated previously, implementation of the site assessment work plan is long overdue. We understand also that the interim recovery program we approved in September 1990 also has not been started. Therefore, your compliance with the 14 February 1992 deadline is crucial . Noncompliance may result in our recommendation of the C&A to the Board. Regardless of the C&A, Board staff oversight is necessary to ensure that the Port and the TC abate the pollution's threat to the ground water quality by adequately cleaning up the site. The Aboveground Petroleum Storage Act (APSA) allows the Board to recover reasonable expenses incurred in overseeing the cleanup and abatement efforts which result from a spill or leak at a tank facility. Reimbursed monies for staff oversight will be deposited in the Environmental Protection Trust Fund (EPTF) , created by the APSA. Therefore, the Port is required to reimburse the EPTF for monies expended by the Board to oversee the cleanup of the terminal 's soil and ground water.