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L. McMahan <br /> 15 June 2018 <br /> Page 2 of 2 <br /> BACKGROUND INFORMATION: <br /> Rough and Ready Island, Stockton, California, is the location of the former U.S. Naval <br /> Supply Annex Stockton. The Navy conveyed the property to the Port over the course of <br /> 2000 to 2011. Past practices at the island have resulted in the release of chemical <br /> contaminants to the environment. The GMWP proposes a plan to monitor chemicals in, <br /> and quality of, groundwater and surface water throughout RRI as well as address data <br /> gaps identified in current monitoring activities. ERAS originally provided comments on <br /> the draft GMWP in a 10 May 2018 memorandum from E. Fendick to L. McMahan. The <br /> Port provided a response to those comments in a 1 June 2018 electronic submittal, and <br /> this memorandum provides ERAS's follow-up comments on the response. <br /> SCOPE OF REVIEW: <br /> ERAS reviewed the response to DTSC and Regional Water Quality Control Board <br /> (RWQCB) comments on the GMWP and PFAS Memo to evaluate whether the Port <br /> addressed to ERAS's satisfaction the issues raised in ERAS's original comments. <br /> GENERAL COMMENT: <br /> The Port response to ERAS's comments defers any ecological evaluation of surface- <br /> water chemistry to future Preliminary Endangerment Assessments (PEAs). The <br /> response also indicates the planned evaluation of media-specific chemicals of concern <br /> (COCs) in the context of a remedial investigation/feasibility study which is to be <br /> submitted for agency review and concurrence. The deferral is a lost opportunity for the <br /> GMWP to provide useful information to ecological risk assessment of RRI ecological <br /> resources. Nonetheless, future PEAs will need to address the concerns expressed in <br /> ERAS's original comments: <br /> • Screening criteria based on aquatic ecological receptors, not drinking water <br /> standards; <br /> • An expanded roster of COCs; <br /> • Evaluation of filtered and unfiltered water samples; <br /> • Collection of surface-water samples from drainage channels that may not be <br /> associated with specific installation restoration sites (e.g., GMWP sample <br /> location SW-06); and <br /> • Collection of surface-water samples at periodic intervals to address seasonal <br /> variation. <br /> Reviewed by: J. Michael Eichelberger, Ph.D., Staff Toxicologist <br /> HERO—ERAS Cal Center <br /> Concurrence: Brian Faulkner, Ph.D., Unit Chief <br /> HERO—ERAS Cal Center <br />