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GROUND WATER INVESTIGATION WORK PLAN BULK TERMINALS SITE, PORT OF STOCKTON, STOCKTON, CALIFORNIA Metropolitan operates a second, adjacent zero-discharge storm water retention pond (Figure 2) under a National Pollutant Discharge Elimination System (NPDES) permit (No. CA 0084174). Brown and Caldwell produced three technical reports on the retention pond in response to a Regional Board request in 1997 (Brown and Caldwell, 1998a, 1998b, 1998c). These reports contain details on construction, engineering controls, and water characterization. Metropolitan's storm water retention pond is also sampled and results are reported annually under the terms of the NPDES permit. The Regional Board requested characterization of water "within the surface impoundment at Bay Sulfur" as part of this Work Plan. Since these retention and impoundment facilities are dry throughout the season it will not be possible to sample until the winter rainy season begins. For this reason, surface water sampling is not included in this work plan. Except for the dock area, the site was largely undeveloped prior to 1971. ERS reviewed aerial photographs from the years 1967, 1971, 1979, 1982, 1989, 1994, 1999, 2002 and 2004. From these photographs and historical information provided by the Port, Baker, Bay Sulfur and Metropolitan staff, areas of historically stockpiled materials and the approximate years these materials were present at the site have been compiled in Figure 3. The historical stockpiles shown in Figure 3 represent the approximate maximum extent of stockpiled materials through the site history, and do not correspond with any stockpile at a particular time. 2.1.1 Historical Operations — Sulfur Prill The Port and Bay Sulfur began storing sulfur prill at the site in 1991. Prior to this time, sulfur prill was trucked from an off site Baker warehouse location to the ship-loading conveyor originating at the clay pit (prior to 1991, this area was used to stockpile ione clay). In 1991, the Port began storing sulfur prill processed at Baker's offsite warehouse in the clay pit. The tunnel conveyor system was used to transport clay from this location to the dock. Baker took over responsibility for storing sulfur prill in the clay pit in 1997, when it began leasing the area from the Port. At that time, Baker lined the clay pit with asphalt and installed berms to retain water. In 2003 Baker leased an additional area south of the clay pit and constructed a new production and processing facility, which began production of sulfur prill in August 2004. Bay Sulfur constructed their facility in 1991 after relocating approximately 4,000 metric tons of stockpiled coal (shown on Figure 3). The Bay Sulfur prill is stockpiled on concrete, surrounded by concrete block walls. This plant has processed and shipped prilled sulfur continuously since 1991. 2.1.2 Historical Operations — Coal and Petroleum Coke Coal and/or petroleum coke have been stockpiled since the 1970s in the northern area of the site near the dock. Historically, coal and petroleum coke were stored in the southern portion of the July 2005 Page 3 Environmental Risk Services Corp.