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Port of Stockton - 2 - 21 September 19986 A power hose and sprinkler was located on the dock, connected to the water supply. Tim Loveland, of the Port, stated that the hose is only used when hot work(welding) is conducted on the dock. There was no apparent welding activity at the time of my inspection. I question the need for a power hose to be connected. Without careful supervision and training, a worker would find the hose a convenient and efficient method for cleaning off the dock, the ship loader, and the support timbers under the loader by washing the materials directly into the river. This would be a deliberate act to circumvent BMPs which reflect Best Available Technology Economically Achievable (BAT) and Best Conventional Technology Economically Achievable (BCT), and a violation of the NPDES permit. The ship loader had inadequate dust suppression equipment, and a cloud of sulfur dust spread out over the dock, adjacent roadway and the Port property. John Benedict went to investigate the cause of the dust emission by going up to where the ship loader was dropping sulfur into the ship. I did not participate in the activity as I believed it would necessitate wearing a respirator. Slide photographs were taken of the areas to document my observations. A representative of FGL Laboratories arrived at the site to collect water samples of the Deep Water Channel for Metropolitan Stevedores. Mr. Mogan indicated that the samples were being collected as a part of its NPDES permit required monitoring program. I suggested the sample be collected from the area where sulfur had been spilled into the water. I believe the samples were to be analyzed for pH, COD, suspended solids, electrical conductivity, and metals. Permit Requirements Waste Discharge Requirements Order No. 97-042 (NPDES No. CA0084077) were adopted 28 February 1997 for the Stockton Port District, for Facility-Wide Storm Water Discharges from the Municipal Separate Storm Sewer System and Non-Storm Water Discharges from the Port of Stockton. Non-storm water discharges include all discharges from the Port facility that are not solely comprised of storm water runoff. Discharges :)f spilled material and product handled at the Port directly to a surface water is also considered a non-s-, rm water discharge. Discharge Prohibition A.S. states: "The discharge of material by the Discharger associated with shipping,receiving and storage activities conducted at the Port, such as, but not limited to, sulfur, coal, cement, petroleum coke, raw sugar, copper concentrate, and fertilizers, to a surface water is prohibited. The Discharger shall not be in violation of this prohibition if it demonstrates that the discharge has not caused an exceedance of a water quality objective, and that it has applied best management practices that reflect the Best Available Technology Economically Achievable for nonconventional and toxic pollutants (BAT), and Best Conventional Technology Economically Achievable for conventional pollutants (BCT),to minimize or avoid such discharges." Effluent Limitation B.2. states: "The Discharger shall reduce or eliminate the discharge of pollutants in non-storm water discharges identified in Provision D.9 from facilities operated by the Discharger through implementation of BAT and BCT technologies."