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CLEANUP AND ABATEMENT ORL_ NO R5-2008-0707 -3- MARTIN OPERATING PARTNERSHIP AND THE PORT OF STOCKTON MOLTEN SULFUR PROCESSING PLANT SAN JOAQUIN COUNTY Location/Source EC (umhos/cm) pH (SU) Ponded water adjacent to loading door at northeast side of stockpile area 3,900 3.5 Ponded water on bare earth adjacent to the north side of the stockpile area 18,000 2.1 Ponded water to the southwest of the stockpile area 3,000 2.6 An existing aboveground storage tank (AST), located adjacent to the Hypalon-lined ponds, has a 400,000-gallon storage capacity. During Regional Water Board staff's inspection on 1 December 2006, leachate with a pH of 1.5 SU was being discharged from the existing AST to ground. Sulfur prill stockpiles are not adequately contained to protect waters of the State. Sulfur prill has been allowed to discharge outside the stockpile containment area to surrounding land and to come in contact with stormwater, ponded water, and surface drainage ditches, as documented in staff's inspections in March 2005, November 2006, and December 2006. Based on the field test results, the low pH and high electrical conductivity are significantly greater than what would be expected from non-impacted stormwater. The results indicate sulfur-impacted water, and that the operations are impacting surface water and are a threat to groundwater. A comparison between the groundwater monitoring data obtained in 1991 versus the data obtained in 2003 indicates that the shallow groundwater has been impacted. In 1991, four groundwater wells were installed (MW-1, MW-2, MW-3, and MW-4). Sulfate concentrations in 1991 ranged from 87 mg/L to 440 mg/L, and in 2003 ranged from 597 mg/L to 1780 mg/L. Samples collected in 2003 also had elevated concentration of electrical conductivity that ranged from 1,743 to 3,080 umhos/cm, and total dissolved solids (TDS) ranging from 1,310 to 2,512 mg/L. The discharge of sulfur at this facility has caused groundwater concentrations of sulfate to increase. The table below shows the changes over time to the sulfate concentration in shallow groundwater wells with respect to wells that were installed prior to the start of operations in 1991. Groundwater monitoring well MW-1 is sidegradient to the operations. Historical Sulfate Concentrations milli rams/liter Date MW-1 MW-2 MW-3 MW-4 8 August 1991 410 87 400 440 23 June 2003 597 1780 1412 1478 15 November 2005 480 860 1200 1200 14 February 2007 450 not analyzed 1100 not analyzed 24 May 2007 410 not analyzed 1000 not analyzed 8 August 2007 470 not analyzed 1100 not analyzed