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ED.UNO G.BRowN JR. <br /> GOVERNOR <br /> C A l I E O R N l♦ MC ETAR FO W ORDRi0UE2 <br /> WaterBoards ENVIRONMENTAL PROTECTION <br /> Central Valley Regional Water Quality Control Board <br /> 25 June 2018 <br /> Jeffrey D. Wingfield <br /> Port of Stockton California <br /> P.O. Box 2089 <br /> Stockton, California 95201 <br /> CENTRAL VALLEY WATER BOARD RESPONSE TO: RESPONSE TO DTSC AND RWQCB <br /> COMMENTS ON THE GROUNDWATER MONITORING WORK PLAN AND FINAL ROUGH <br /> AND READY ISLAND GROUNDWATER MONITORING WORKPLAN, PORT OF STOCKTON <br /> ROUGHA ND READ ISLAND, SAN JOAQUIN COUNTY <br /> Dear Mr. Wingfield, <br /> Central Valley Regional Water Quality Control Board (Central Valley Water Board) staff have <br /> reviewed the Port of Stockton's 1 June 2018 Response to DTSC and RWQCB Comments on <br /> the Groundwater Monitoring Work Plan (RTCs) and the Final Rough and Ready Island <br /> Groundwater Monitoring Work Plan (Final Work Plan). Submitted by email on behalf of the Port <br /> of Stockton by Geosyntec Consultants (Geosyntec), the RTCs and Final Work Plan address <br /> regulatory comments made on the 9 April 2018 Draft Rough and Ready Island Groundwater <br /> Monitoring Work Plan (Draft Work Plan) at the Port of Stockton Rough and Ready Island (Site) <br /> in Stockton. San Joaquin County. <br /> The Department of Toxic Substances Control (DTSC) responded to the Port of Stockton's RTCs <br /> and Final Work Plan on 19 June 2018. DTSC expressed several concerns regarding the Port of <br /> Stockton's responses but still approved the Port's proposed sampling activities and schedule. <br /> DTSC primary concerns include: <br /> 1. The Final Work Plan does not include sampling for all contaminants of concern (COC), <br /> 2. Surface water sampling will utilize a bladder pump instead of a pump more suitable for <br /> volatile organic carbon (VOC) analyses such as a peristaltic pump, <br /> 3. The Port of Stockton is deferring an ecological evaluation of surface water chemistry to a <br /> future Preliminary Endangerment Assessment (PEA), <br /> 4. The Port of Stockton intends to submit a COC evaluation report as part of a remedial <br /> investigation/feasibility study after completion of the first phase of the Final Work Plan is <br /> complete, <br /> 5. The Final Work Plan only proposes sampling monitoring wells that had COCs above <br /> respective maximum contaminant levels (MCLs) or detections of total petroleum <br /> hydrocarbons (TPH) that exceeded 100 pg/L in the most recent sampling event, and <br /> 6. The Final Work Plan does not include sampling for all metals that would be important in <br /> future risk assessments. <br /> Central Valley Water Board staff echo DTSC's concerns and comments in their 19 June 2018 <br /> response letter to the RTCs and Final Work Plan. However, Central Valley Water Board staff <br /> concur with the Port of Stockton's responses to specific Central Valley Water Board comments <br /> KARL E. LONGLEY SCD, P.E., CHAIR � PATRICK PULUPA, EXECUTIVE OFFICEF <br /> l 1020 Sun Center Drive#200,Rancho Cordova.CA 95670 1 www.waterboards.ca.gov/centralvalley <br /> r,*RECYCLED PAPER <br />