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Alan C. Lloyd, Ph.D <br />Agency Secretary <br />California Reeonal Water Quality Antrol Board <br />Central Valley Region <br />Robert Schneider, Chair <br />Sacramento Main Office <br />11020 Sun Center Drive #200, Rancho Cordova, California 95670-6114 <br />Phone (916) 464-3291 • FAX (916) 464-4645 <br />http://www.waterboards. ca.gov/centralval I ey <br />Arnold <br />Schwarzenegger <br />Governor <br />9 September 2005 <br />Captain Leif Gistrand, Manager <br />Metropolitan Bulk Terminal <br />P.O. Box 986 <br />Stockton, CA 95201-0986 <br />Sp 1 3 2005 <br />EM/IRQNMEIVI- HEALTH PER1vIIT/SERVICES <br />METROPOLITAN STEVEDORE COMPANY (MSC) SHORT-TERM PLAN TO MANAGE SULFUR, <br />PORT OF STOCKTON, SAN JOAQUIN COUNTY <br />We have reviewed Metropolitan Stevedore Company Short-Term Plan To Manage Sulfur (Plan) <br />received on 15 July 2005. The three-page report outlines a short-term strategy to managing sulfur at the <br />Port of Stockton. The Plan focuses on six areas of concern. The following are staff concerns regarding <br />the Plan: <br />Area No. 1: <br />More information shall be provided that describes how the sulfur-laden wash water will be contained, <br />stored and disposed of. As indicated in our 12 April 2005 inspection report, staff is concerned about the <br />low pH of this water and the potential impacts to groundwater. Sulfur-laden wash water should not be <br />disposed of in MSC's storm water pond or any other holding pond that is not constructed to protect <br />groundwater. If MSC intends to continue to use the onsite storm water pond for sulfur-laden wash <br />water, then a Report of Waste Discharge for the construction of a surface impoundment pursuant to Title <br />27, California Code of Regulations, Division 2 (Title 27) Section 21710 shall be submitted. <br />Area No. 2: <br />MSC proposes to grade the top three inches of topsoil. Staff does not support this approach. Sulfur <br />impacted soil shall be scraped and removed from this area. Additional information should be provided <br />that supports the conclusion that 3 inches is adequate to remove all sulfur impacted soil. In addition, <br />information should be provided to adequately characterize the scraped off material such that it can be <br />properly stored and disposed of. <br />As outlined in the above comments for Area No. 1, sulfur-laden wash down water shall not be <br />discharged to the storm water pond. <br />California Environmental Protection Agency <br />%.3 Recycled Paper