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,inda S. Adams <br />Secretary for <br />Environmental <br />Protection <br />Captain Leif Gistrand, Manager <br />Metropolitan Bulk Terminal <br />P.O. Box 986 <br />Stockton, CA 95201-0986 <br />Mr. Dave Wilkey, General Manager <br />Bay Sulfur <br />P.O. 982 <br />Stockton, CA 95201-0982 <br />Adry--wLi_ to-A <br />Arnold <br />chwarzenegger <br />Governor <br />California Reg al Water Quality Control - Ard <br />Central Valley Region <br />Robert Schneider, Chair <br />Sacramento Main Office <br />11020 Sun Center Drive 4200, Rancho Cordova, California 95670-6114 <br />Phone (916) 464-3291 • FAX (916) 464-4645 <br />http://wwwwaterboards.ca.govicentralvalley <br />IWO \.\91'r <br />JUN 8 2006 <br />ENVIRONMM- HEALTH <br />PER <br />6 June 2006 <br />Mr. Jeff Kasper, Deputy Director <br />Port of Stockton <br />P.O. Box 2089 <br />Stockton, CA 95201-2089 <br />Mr. Chuck DeJong, Plant Manager <br />N.J. Baker & Bro., Inc. <br />P.O. Box 2089 <br />Stockton, CA 95201 <br />GROUND WATER INVESTIGATION AND FEASIBILITY STUDY, PORT OF STOCKTON <br />BULK TERMINAL SITE, STANISLAUS COUNTY <br />Board staff (staff) has reviewed the <br />Ground Water Investigation and Feasibility Study for the <br />Bulk Terminal Site at the Port of Stockton received on 24 FebrLwy 2006. The report finds that <br />at a minimum groundwater has been impacted by increased concentrations of sulfur. The <br />sulfur impacts were caused by the inadvertent discharges of sulfur blown to adjacent land and <br />spilledfrom conveyers. Rainwater leached sulfur from the soils and percolated to impact <br />groundwater. The Feasibility Study recommends groundwater monitoring as the remedial <br />alternative. This monitoring willdetermine if the existing control measures (wind screens, <br />maintenance of conveyors) are affective. No further measures to prevent releases from these <br />facilities or cleanup of sulfur already released are proposed. <br />Staff disagrees with the conclusions of the feasibility study, and believes further investigation, <br />more extensive corrective actions are necessary to remediate sulfur releases and additional <br />sulfur control measures may be required. Sulfur concentrations in the shallow soil are as high <br />as 20,000 mg/Kg. These sulfur impacted soils will continue to be a source of surface and <br />groundwater pollution. There is limited discussion on the sulfur piles themselves. Further <br />investigation of the sulfur pile areas is necessary to determine if the sulfur pads are effectively <br />controlling stormwater and preventing impacts to groundwater. Also, of the proposed <br />groundwater monitoring has no well-defined objectives or additional action trigger language. <br />Below are specific comments and recommendations: <br />1. Very high soil sulfur concentrations were detected in soils during the investigation. <br />These soils are a continuing source of groundwater pollution and the extent of this soil <br />pollution needs to be better defined. Also, soils east of Bay Sulfur should be <br />investigated to determine if this area is a source of groundwater and surface water <br />pollution. Therefore, a work plan is required describing a soil investigation to determine <br />the lateral and vertical extent of the known areas of high sulfur concentrations and of <br />the soils east of the Bay Sulfur site. <br />California Environmental Protection Agency <br />Ci Recycled Paper