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I. Introduction and Background Metropolitan Stevedore Company (MSC) owns and operates a general and bulk cargo handling facility at the Port of Stockton (Port) in the City of Stockton, San Joaquin County. MSC is located toward the western end of the Port, south of the Port Road A [main rail classification yard, see Figure 1. MSC operates a marine bulk vessel loading facility located at Dock 12, an integrated conveyor system for the transfer of bulk materials to and from Dock 12, and rotary rail car dumper. MSC operates the bulk materials loading facility located at and near Dock 12, in the Port. The facility consists of: (1) two adjoining leased parcels of 10.0 acres located approximately 700 linear feet from Dock 12; and (2) a right-of-way connecting the leased area to Dock 12, on which MSC operates a conveyor system used for transferring bulk materials from the leased area and adjacent areas to Dock 12 for ship loading. MSC's lease includes a total of 14.69 acres, of which 4.69 acres is subleased to Bay Sulfur (BSU), wherein BSU processes molten Sulfur and stockpiles it as periled sulfur in a contained facility (see figure 1). The BSU facility is completely contained within a walled and bermed facility. The 10.0 acres actually occupied by MSC is in two adjoining parcels, one of which is rectangular, containing the former petroleum coke stockpile area, rotary car dumper, rail loop track, and the office. The remaining 5.0 acre parcel is irregular in shape and located between the rectangular parcel and BSU's facility. In 1991, in order to fulfill its property due diligence, MSC retained Dames and Moore to conduct a baseline ground water quality report, titled "Baseline Investigation Report" and a "Preliminary Site Assessment Report" for the Audit Area III (MSC's former Petroleum Coke storage area). As such, four ground water monitoring wells were installed by Dames and Moore's contractor in 1991 (see Figure 2). These wells were strategically placed in order to provide both ground water quality information immediately underneath Area III (MW-1 and 4), as well as for the purpose of establishing ground water direction in the immediate vicinity of MSC's leased land from the Port. In connection with MSC's application filed with the San Joaquin County Environmental Health Department (SJCEHD) to close the above-referenced wells in place, in April 2003, MSC was requested by the SJCEHD and the Central Valley Regional Water Quality Control Board (CVRWQCB) to conduct a one time ground water sampling and analysis of monitoring wells 1 through 4. MSC, in good faith, and as a "cooperating party" has conducted the following actions to date: 1