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CLEANUP AND ABATEMENT ORD R5-2008-0710 -3- HJ BAKER & BRO. INC AND THE PORT OF STOCKTON MOLTEN SULFUR PROCESSING PLANT, SAN JOAQUIN COUNTY Currently, sulfur prill is stored outside, in uncovered stockpiles on asphalt. Board staffs inspection on 25 August 2008 shows that, where inspected, the asphalt has a typical cracked or "alligator" appearance that indicates deterioration of the asphalt. The facility has not previously been regulated by Waste Discharge Requirements (WD Rs). The entire Site is enrolled under the state-wide General Permit for Industrial Storm Water (WDID 5S391000860). According to Baker's 2 April 2008 letter, non-contact storm water runoff flows south to two storm drains that connect and then flow to a drainage ditch west of a former blending and transfer building. From here, the non- contact surface water runoff discharges to Washington Street and the Port of Stockton's municipal storm water drainage system. Rainfall runoff from the eastern roof of a blending and transfer building flows to downspouts that discharge to a drainage ditch along the eastern edge of building. This ditch also receives and conveys runoff from Stork Road, not associated with the facility. Previous to enrollment under WDID 5S391000860, Baker was enrolled under WDID No. 5639S000860. IMPACTS TO GROUNDWATER AND SURFACE WATER When rainwater contacts sulfur prill stockpiles, a solution is formed that contains soluble materials extracted from the prill. This solution is acidic, with elevated concentrations of electrical conductivity and sulfate. Typically, this solution has a pH range of 1.5 to 6.5 Standard pH Units (SU), an electrical conductivity range of 3,200 to 18,000 umhos/cm, and sulfate range of 2,300 to 9,800 mg/L.1 For comparison (although not necessarily applicable at this site), the USEPA Primary Maximum Contaminant Level (MCL) for sulfate in drinking water is 500 mg/L; the California short-term upper level for electrical conductivity in drinking water is 2,200 umhos/cm; and the USEPA minimum Secondary MCL for pH in drinking water is 6.5 SU. The Basin Plan's water quality objectives for pH in surface water ranges from 6.5 to 8.5 SU. The solution exceeds these criteria. Throughout this Order, this acidic solution with elevated concentrations of electrical conductivity and sulfate is referred to as "sulfur-contact water". In July 1997 Baker performed an environmental site assessment (SA) of the 65 Stork Road facility. Based on data presented in the SA, as early as 1997 the sulfur-contact water was discharged to bare earth and sulfur fines had migrated off Site. The SA reported that in 1997 the sulfur piles were up to 20-feet high, and the Clay Pit was in "poor condition," and there was significant evidence of off-site discharges of non- storm water. There were no windscreens. In addition, the SA reported that the Site was only partially paved, with major breaches in the partial containment berm. Moreover, there was strong evidence of tracking of fine particulate sulfur from the storage area to Washington Street was evident. Water that was being pumped from the below grade hopper had a pH of 1.9, and was being discharged for percolation to I Environmental Site Assessment Proposed Lease Facility, Page 22, July 1997: Regional Water Board inspection report March 2005