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STATE G. CALIFORNIA - Environmental Protect—n Agency PETE WILSON, Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD CENTRAL VALLEY REGION 3443 Routier Road, Suite A , Sacramento, CA 95827-3098 r 3 } PHONE: (916) 255-3000 P, h: I FAX: (916) 255-3015 1 Mr. Wayne Smith 2 October 1994 City of Stockton Project Manager City of Stockton Department of Public Works City Hall, 425 N. El Dorado Street Stockton, CA 95202-1997 PROPOSED SEWER PROJECT AT ROUGH AND READY ISLAND, ACROSS NAVAL CONINIUNICATIONS STATION STOCKTON, SAN JOAQUIN COUNTY On 7 September 1994, we met with you, Mr. Ronald Weldum of the Department of Public Works, and Mr. Mark Madison of the Department of Municipal Utilities, to discuss the City of Stockton's proposed installation of two pressure sewer pipelines across the Naval Communications Station (NCS) Stockton facility located on Rough and Ready Island. During the meeting, we conveyed our concerns that this portion of the City's proposed sewer pipeline project may result in discharges of waste that could affect the quality of ground and/or surface waters in the area of Rough and Ready Island. As we discussed, the City is aware of the potential for contaminated soils and ground water to be encountered in the routing of this project. Our primary concerns include the containment and disposition of any contaminated soil resulting from excavation activities, disposal of any contaminated ground water resulting from dewatering, and the potential for the pipelines and their backfill to provide a conduit for contaminant migration after construction is completed. Pursuant to Section 13267 of the California Water Code, the City of Stockton must submit a Work Plan to address our concerns regarding the potential discharge of contaminated soil or ground water. These concerns, including specific elements which must be addressed in the ;:'ork Plan are described in more detail below. The Porter-Cologne Water Quality Control Act (Porter-Cologne Act), Division 7 of the California Water Code, commencing with Water Code Section 13000, provides that each Regional Water Quality Control Board (Regional Water Board) be the principal state agency with primary responsibility for the coordination and control of water quality within its region. Section 13264 of the Porter-Cologne Act prohibits any discharge of waste that could affect the quality of waters of the state prior to filing a report of waste discharge, containing information which may be required by a Regional Water Board. Furthermore, Section 13267 of the Water Code states, in part, that a Regional Water Board may require any person discharging, or proposing to discharge, waste that could affect the quality of waters within its region to furnish those technical or monitoring reports as the Regional Water Board may specify. As we discussed during the meeting, pipeline construction activities proposed by the City of Stockton, which include the excavation of soils and dewatering of ground water, may encounter areas on Navy property that contain soil and/or ground water contamination. The Board provides