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Mr. Jason Cashman June 19, 2018 Page 2 of 4 identification of source locations will be conducted over the next three months. While omitting known contaminants from sampling will result in significant overall project delays, DTSC agrees identification of COCs will advance the site characterization and remedy selection process. DTSC requests the Port submit the media-specific evaluation of COCs by August 31, 2018. DTSC's May 11 comments requested the Port revise the GMWP surface water sampling protocol to collect samples near the bottom of the channel wherever water is deep enough to do so. The response to comments indicates "The SOP for surface water sampling has been revised to state 'If the water is more than five feet deep the samples will be collected from beneath the water surface. Peristaltic tubing will be attached to a pole or weight and suspended to a depth approximately one foot above the bottom of the channel." The Final GMWP in fact made no changes to the Standard Operating Procedure for Surface Water Sampling (SOP). Further, DTSC has previously commented on the inappropriateness of using a peristaltic pump for collecting volatile organic compounds, resulting in the selection of a bladder pump for sampling of wells. Please revise the SOP to use a pump suitable for VOCs for surface water sampling whenever the water is deep enough to do so. Please note some pumps (e.g., bladder) can operate in water less than five feet deep. Please submit the revised SOP by June 25, 2018. As outlined in the above comments and the enclosed DTSC memoranda, the GMWP does not achieve its stated purpose of providing a comprehensive groundwater and surface water sampling program. All issues will need to be resolved in order to select a remedy. Nonetheless, DTSC approves of the Port conducting the proposed sampling. As the Port continues to characterize groundwater contamination at Rough and Ready Island, DTSC refers you to recent guidance on groundwater contamination that discusses limitations of strategies used in prior decades, and offers an approach which results in better site characterization and remediation. For example, the Interstate Technology and Resources Council's Integrated DNAPL Site Strategy guidance manual provides a multi-compartment approach to understanding groundwater contamination sites, and selecting a remedy. While the primary focus of the ITRC guidance is chlorinated-solvent sites, other types of contaminated sites (e.g., petroleum, mixed contaminants, etc.) can use the same fundamental process described in the ITRC guidance. The ITRC guidance is available at https://www.itrcweb.org/guidancedocuments/integrateddnapIstrategy_idssdoc/idss-1.pdf.