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Sacramento Main Office <br />11020 Sun Center Drive #200, Rancho Cordova, California 956706114 <br />Phone (916) 464-3291 • FAX (916) 464-4645 <br />http://www.waterboards.ca.govicentralvalley <br />Arnold <br />Schwarzenegger <br />Governor <br />AS California Regional Water Quality Control Board <br />Central Valley Region <br />Robert Schneider, Chair <br />28 September 2005 <br />Alan C. Lloyd, Ph.D. <br />Agency Secretary <br />Peter Weiler and Steven Michaelson <br />Environmental Risk Services Corporation <br />2121 N. California Blvd., Suite 820 <br />Walnut Creek, CA 94596 <br />GROUNDWATER INVESTIGATION INVESTIGATION WORK PLAN, BULK TERMINALS SITE, PORT OF <br />STOCKTON, SAN JOAQUIN COUNTY <br />We have reviewed the Response to Comments, Groundwater Investigation Work Plan, Bulk Terminals <br />Site, Port of Stockton. The following outlines our final comments: <br />Location of C-7 and C-8: We understand that ERS does not recommend drilling within the coal <br />piles. The borings shall be advanced in an area that adequately characterizes the soil and <br />groundwater beneath the coal stockpile. <br />Soil and Groundwater Analytical Methods: We concur with the approach of utilizing the citrate <br />extract if the pH is at or below 6 and the USEPA analytical methods. <br />Soil and Groundwater Analysis: Regional Board does not concur with the proposed reduction of <br />the soil and groundwater analysis. The purpose of this initial groundwater monitoring event is <br />for the characterization of the soil and groundwater beneath the site. Under low pH conditions, <br />metals have the ability to become more mobile, thereby potentially increasing the plume size and <br />direction. In addition, it is important that all of the wells be analyzed for the same constituents so <br />that the wells can be compared with each other and with background. <br />Therefore, the soil and groundwater samples collected as described in the sampling plan shall be <br />analyzed for: bicarbonate, calcium, magnesium, sulfate, sodium, nitrate, chloride, sulfur, title 22 <br />metals, pH, TDS, alkalinity, EC, THE, BTEX and PAHs. <br />Upon completion of the initial round of sampling, further monitoring, if warranted, may be <br />significantly reduced. <br />California Environmental Protection Agency <br />(.3 Recycled Paper