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Port of Stockton Bulk Tern - 2 - 6 June 2006R Ground Water Investigation and Feasibility Study Contaminated soils that pose a significant risk to groundwater or surface water must be remediated. The remediation plan should establish soil cleanup levels and a procedure for removal or isolation of soils that are a threat to water quality. The remediation of sulfur polluted soils would also make the monitoring option in the Feasibility Study more likely to succeed, because much of the source of the pollution has been removed. A soil remediation plan is required. No investigation was done to determine if the sulfur storage areas themselves are a potential source of the detected groundwater pollution. The stormwater runoff and any other liquid in the storage areas are a designated waste and therefore the storage area must meet the performance standards of Title 27 California Code of Regulations, Division 2 (Title 27). An evaluation of sulfur storage areas and their potential threat to water quality is required. The recommend remedial alternative of monitoring seems to have no objectives or remedial goals besides to monitor the extent of the groundwater contamination. Remedial action trigger language is required to determine when the proposed remedial alternative of recent facility improvements and monitoring has failed and further action is required. The proposed groundwater monitoring system for the remedial alternative needs additional wells to adequately monitor groundwater both upgradient and downgradient of the individual sulfur facilities, and to monitor the conveyer area. Attached is Figure 10 from the report showing proposed additions to the monitoring system. Monitoring well B1 would be upgradient of H.J. Baker and B2 downgradient. B3 would monitor the conveyer belt area. We also proposed to move MW-5 south so it is less likely to be affected by H.J. Baker and be an upgradient well to Bay sulfur. The monitoring plan should be changed and implemented this summer. Submit a report addressing the above concerns and issues by 15 July 2006. The report should include a schedule to complete each task. All soils cleanup should be completed before 2006-2007 rain season and the monitoring wells installed. If you have any question, please call me at (916) 464-4626 or e-mail me at vizzo@waterboards.ca.gov , / VICTOR J(IZZO Senior Engineering Geologist cc: Margaret Lagorio, San Joaquin County Environmental Health Department, Stockton Mr. Jeffrey Wingfield, Jones and Stokes, C/O Port of Stockton, Stockton Nicole Granquist, Downey Brand, LLP, Sacramento Mr. Zachary Walton, Paul, Hastings, Janofsky and Walker, LLP, San Francisco Charels F. Timms, Broiles & Timms, LLP Mr. Peter Weiler, ERS Corporation, Walnut Creek INITIALS/Dnve\Folder\DocumentName