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Port of Stockton - 3 - 21 September 1998 Provision D.9.c. covers discharge of material associated with loading and unloading activities by the Discharger, and states: "The Discharger shall implement BMPs forthwith that reflect BAT and BCT technologies to prevent or minimize the direct discharge of materials associated with shipping, receiving and storage activities." "The Discharger shall evaluate the effectiveness of the BMPs implemented and shall revise, amend, or add BMPs if the Discharger determines the BMPs are not effective, or at the request of the Executive Officer." Inspection Follow-up Subsequent to the inspection, I reviewed the Independent Audit Report submitted by the Port on 12 June 1998. Table 2 of the report includes a section of findings with regard to the Port's sulfur loading dock. The audit recommends that dry methods of cleanup be evaluated for their effectiveness at cleaning up fugitive dusts and materials, and only use wet methods (e.g. power hoses) if all rinse waters can be captured. The report also recommends that if the operational controls are not effective, the Port should implement hardware-based controls, such as enclosed conveyors. By letter dated 14 September 1998, the Port stated it is installing concrete berms and a corrugated plastic shed to provide complete containment of the conveyor system where it runs along the ground, and will also berm and completely enclose the above ground portions of the conveyor system. It also installed additional tarps on the conveyor belt that inclines to the ship loader, the collection chute, and will place a catchment tarp below the ship loader. These controls will be helpful, and are a significant step towards improving the quality of storm water runoff in the area. I continue to question whether tarp usage to collect spills will be an effective solution to prevent spills in the vicinity of the inclined conveyor and ship loader, as they may be difficult to properly implement by those performing the work. The problem of sulfur dust emissions from the ship loader also does not appear to be addressed. Industrial Permit Coverage The conveyor operations at the Port are not now covered by the General Industrial Permit. However, comments were made during the audit process that conveyor operations at the Port are subject to the industrial permit. Based on a legal review of the audit comments, this office reevaluated the conveyor operations and determined that industrial permit coverage is required. The basis for this conclusion is that the conveyor operation is represented by SIC Code# 4491, Marine Cargo Handling. This SIC Code is under Category 8 of Attachment 1 (Facilities Covered by this General Permit) in the Industrial Permit as a Transportation Facility with other operations that are associated with industrial activity. In the Definitions (Attachment 4) under "Storm Water Associated with Industrial Activity", the permit states: "For facilities identified in Categories 1 through 9 of Attachment 1 of this General Permit, the term includes,but is not limited to, storm water discharges from industrial plant yards, ...material handling sites, ...sites used for storage and maintenance of material handling equipment."