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ram <br />July 14, 2005 <br />ENVIRONMENTAL RISK SERVICES <br />CORPORATION <br />Mr. Thomas R. Pinkos <br />Executive Officer <br />California Regional Water Quality Control Board <br />Central Valley Region <br />11020 Sun Center Drive, i`200 <br />Rancho Cordova, California 95670-6114 <br />OCr 1 2005 <br />• ENVIRONWOJT l',EALTH <br />PERMIT/SEriVICES <br />Subject: Ground Water Investigation Work Plan <br />Bulk Terminals Site, Port of Stockton, Stockton, California <br />Dear Mr. Pinkos: <br />On behalf of the Port of Stockton, H.J. Baker & Bro., Inc., Metropolitan Bulk Terminal and Bay <br />Sulfur (collectively referred as the "Parties"), ERS is pleased to submit this proposed work plan <br />for ground water investigation (the "Work Plan"). The Work Plan is responsive to the Regional <br />Board's letters dated 12 April 2005 and 2 June 2005 requiring the Parties to prepare a ground <br />water investigation work plan to assess the lateral and vertical extent of ground water impacts <br />from existing and historical activities in the area. ERS will implement the Work Plan after <br />obtaining Regional Board approval. <br />The Regional Board's letter dated 2 June 2005 requires the Parties to prepare by 1 December <br />2005 a feasibility study for corrective action per Title 27 based on the results of the ground water <br />investigation. Title 27 applies to discharges of waste to land for treatment, storage or <br />disposal. None of the Parties discharge waste to land at their respective sites, including sulfur <br />drift, for treatment, storage or disposal. Their operations involve the manufacturing, storage <br />and transportation of product, namely sulfur prill. For this reason the Parties question the <br />application of Title 27 to the facts at hand. Nevertheless, the Parties are fully committed to <br />addressing potential impacts, if any, to water quality as a result of their operations in a manner <br />satisfactory to the Regional Board. <br />If you have any questions, please contact me at (925) 938-1600 extension 101. <br />Sincerely, <br />Mark J. O'Brien <br />ENVIRONMENTAL RISK SERVICES CORPORATION <br />cc: Victor Izzo, CVRWQCB <br />2121 N. California Blvd., Suite 820, Walnut Creek, California 94596 <br />925 938 1600 - erscorp.us