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CLEANUP AND ABATEMENT ORD R5-2008-0710 -7-
<br />HJ BAKER & BRO. INC AND THE PORT OF STOCKTON
<br />MOLTEN SULFUR PROCESSING PLANT, SAN JOAQUIN COUNTY
<br />In a joint letter dated 20 May 2005, Baker, Port, and other dry bulk operators
<br />requested extensions to 1 August for submittal of the workplan and to 1 December
<br />2005 for submittal of the investigation results, feasibility study and corrective action
<br />measures, and Report of Waste Discharge.
<br />To prevent further delays, on 2 June 2005 the Central Valley Water Board ordered the
<br />submittal of technical reports pursuant to California Water Code section 13267 and
<br />provided extension due dates of 15 July 2005 and 1 December 2005. Further, Baker,
<br />Port, and other dry bulk operators were jointly directed to submit a short-term plan to
<br />manage sulfur in a manner that would prevent release outside the containment area
<br />or from the conveyance structures.
<br />On 15 July 2005 and 9 September 2005, Baker, Port, and the other bulk storage
<br />operators submitted a joint groundwater investigation work plan and a Short Term
<br />Sulfur Management Plan, respectively.
<br />In a letter received 14 February 2006, Baker, Port, and the other bulk storage
<br />operators jointly requested an extension for submittal of the ROWD from 1 December
<br />2005 to 15 March 2006. On 17 February 2006 the Central Valley Water Board sent a
<br />joint Notice of Violation to Baker, Port, and the other bulk storage operators for failure
<br />to submit a technical report, including an ROWD, by 1 December 2005. However, in
<br />an 8 March 2006 letter, the Board did not recommend that enforcement actions be
<br />pursued if the ROWD was submitted by 15 March 2006. Baker, Port, and the other
<br />bulk storage operators jointly submitted the ROWD on 15 March 2006.
<br />On 24 February 2006, Baker, Port, and the other bulk storage operators jointly
<br />submitted its Groundwater Investigation and Feasibility Study, Bulk Terminals Site
<br />(Report). The Report concluded that relatively elevated concentrations of total sulfur
<br />and sulfate are present in groundwater in the immediate vicinity of the Bulk terminals
<br />site and in the general area of historical and current sulfur prill storage and operations.
<br />The Report recommended the installation and monitoring of additional groundwater
<br />wells. Subsequently, eight groundwater monitoring wells were constructed in a lower
<br />sandy aquifer. Jointly, Baker, Port, and the other bulk storage operators have
<br />monitored these new wells, two of the existing wells, and have submitted three
<br />quarterly groundwater-monitoring reports (first, second, and third quarters of 2007).
<br />Attachment B shows the locations of all groundwater monitoring wells.
<br />In a letter submitted 2 April 2008, Baker stated that it would install a 500,000 gallon
<br />above ground storage tank (AST) for storage of sulfur-contact water (in lieu of storing
<br />ponded sulfur-contact water on degraded asphalt), install pavement outside the Clay
<br />Pit on remaining bare areas where sulfur could accumulate, replace damaged wind
<br />screens, and fill in the below grade vault.
<br />In a 13 August 2008 email, Baker stated that all areas outside the Clay Pit have been
<br />paved, the lower portions of the wind screens have been installed, the work on the
<br />concrete vault is proceeding, an engineering firm has been retained to work on the
<br />AST foundation, and communications have begun with the tank manufacturer to
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