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Port of Stockton -7- 2 June 2005 San Joaquin County (MW-1 through MW-4) in the immediate vicinity of MSC's property which is leased from the Port of Stockton. MSC collected baseline samples from these wells in 1991, prior to their start up, and re-sampled in June 2003. Sulfate concentrations in 1991 ranged from 87 mg/L (MW-1) to 440 mg/L (MW-4) and in 2003 increased to 597 mg/L (MW-1) to 1780 mg/L (MW-2). Samples collected in 2003 also had elevated concentrations of EC ranging from 1743 1.unhos/cm to 3080 p.mhos/cm, TDS ranging from 1310 mg/L to 2512 mg/L, and sulfur ranging from 197 to 587 mg/L. These concentrations exceed water quality objectives, and indicate an impact to water quality. As noted in our inspection report, dated 8 April 2005, Board staff determined the sulfur piles were not adequately contained to protect waters of the state. Data collected during our inspection, as well as MSC's groundwater data, support Board staff's conclusion that sulfur has impacted water quality. The sulfur piles themselves are not considered a waste. However, leachate is generated as rainfall percolates through the stockpiled sulfur, runs off the piles and discharges as storm water. This leachate is considered a waste material because of its acidic properties. In addition, as noted during the inspection, there was wind blown sulfur drift from the H.J. Baker and Bay Sulfur piles. This sulfur drift settled in ponded storm water, reducing the pH and increasing the EC. The ponded storm water is a potential source of groundwater contamination. Field readings of pH and EC, and historical groundwater data, have lead staff to conclude that the sulfur drift and/or storm water runoff has impacted water quality. Therefore, pursuant to Section 13267 of the California Water Code (CWC), you are directed to provide the following written technical reports. The reports shall be prepared under the direction of a California Registered Engineer or Certified Engineering Geologist, and signed and stamped by that person. By 15 July 2005, the Discharger shall submit a groundwater investigation work plan. The groundwater investigation shall assess the lateral and vertical extent of groundwater impacts from the existing and past activities (sulfur, copper concentrate, coal and petroleum coke storage) at the H.J. Baker, Bay Sulfur and MSC sites. A characterization of water within the surface impoundment at Bay Sulfur shall also be provided. By 15 July 2005, the Discharger shall submit a short-term plan to manage the sulfur at the Port of Stockton in a manner that will prevent its release outside the present containment areas or from the conveyance structures for the winter of 2005-2006. This plan shall include the removal of sulfur presently discharged to the surface soils and surrounding roadways adjacent to these facilities. The plan shall include an implementation date no later than 15 October 2005. By 1 December 2005, the Discharger shall submit the following: Results of the groundwater investigation. Feasibility study and corrective action measures for the cleanup of soils, surface water and groundwater per Title 27 California Code of Regulations (Title 27) §20425 (See attached). Report of Waste Discharge (RWD) for long-term containment facilities that comply with Title 27 §21710 (See attached). The RWD shall address the containment of sulfur and sulfur impacted storm water per Title 27 (construction of waste management units) or management practices to prevent the creation of waste (i.e. covered storage facilities and conveyance structures such that designated waste will not be created).