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CLEANUP AND ABATEMENT ORDER PORT OF STOCKTON FUEL TERMINALS -3- SAN JOAQUIN COUNTY f. ST Sevices and Tesoro discharged effluent from oil/water separators directly to unlined surface impoundments. This was discovered in 1986 and 1987, respectively. Both are now hooked up to the City of Stockton sewer. 11. On 16 June 1987, Board staff requested a workplan from the Port for the definition of the entire extent of soil and ground water contamination in the Fuel Terminal Area. 12. On 24 July 1987, a Phase I investigation report was received in addition to a workplan for a proposed Phase II investigation. The report and workplan did not meet the Board ' s objectives, nor did they encompass the scope of work requested in the Board ' s 16 June 1987 letter . This was indicated in a 2 October 1987 letter to the Port. 13. A Phase 1I investigation report and a Phase III investigation workplan were received by the Board on 29 October 1987. A meeting with the consultant working on the ground water investigation and the attorney for the Port was held on 7 December 1987 to discuss the ground water investigation. Four of seventeen wells proposed in the 29 October 1987 workplan were constructed, but further work proposed in the plan was not completed. The four wells were not developed and ground water samples were not taken. 14. A revised workplan for continuation of an overall ground water investigation at the Fuel Terminal Area was received on 7 June 1988 by the Board. The plan was inadequate and proposed even less work than the previously submitted workplan, and did not propose to define the extent of soil and ground water contamination outside the Fuel Terminal Area. 15. Results of a preliminary ground water investigation conducted by several of the Fuel Terminal operators as a group in August 1987 indicted that petroleum hydrocarbons were present in subsurface soils as well as floating on ground water to the east of the Terminal property boundaries. This is documented in the reports, "Ground water Investigation, Phase I: Hydrogeologic Setting and Site History, Petroleum Storage and Handling Terminal " and "Phase 1I : Subsurface Investigation, Petroleum Storage and Handling Terminal , Port of Stockton," prepared by Woodward-Clyde Consultants. 16. Soil and ground water contamination is present in several on- and off-site areas. Determination of the sources of the overall contamination is difficult and has not been done by the Port or the lessees. All of the operators listed in Finding 2, above, store and distribute fuel , and have the potential to pollute soil and ground water. The Port and tenants have control of the land and the ability to control discharges. Based on existing evidence, data, and age of the sites, it is extremely likely that all of the terminals have had spills and/or leaks that have contributed to soil and ground water contamination.