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V 0 .41 California R,, -ional Water Quality Wntrol Board QW; I a Central Valley Region Peter M.Rooney Sacramento Main Office Ed J.Schnabel Secretaryfor Internet Address: http://www.swrcb.ca.gov/—rwgcb5/home.html �01 ' Chair Environmental 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Protection Phone(916)255-3000•FAX(916)255-3015 21 September 1998 N Mr. Alexander Krygsman, Director = Port of Stockton Post Office Box 2089 Stockton, CA 95201-2089 n INSPECTION REPORT, SULFUR LOADING CONVEYOR, PORT OF STOCKTON, SAN JOAQUIN COUNTY Enclosed is a copy of a report covering an inspection of the sulfur loading conveyor owned by the Port of Stockton, and operated by the Stevedoring Services of America. The report indicates that recent conveyor operations caused significant quantities of sulfur to be spilled directly into the Deep Water Channel, onto the dock and its supporting timbers, and onto the ground along the length of the conveyor. The ship loader generates significant quantities of sulfur dust which settles over the Port property and into the Channel. These operations demonstrate that neither the Port nor Stevedoring Services of America has been implementing adequate Best Management Practices (BMPs). Recent improvements proposed by the Port to enclose the conveyor along the ground, and to use an improved tarp collection system on the inclined conveyor and ship loader will be helpful, and are a significant step towards improving the quality of storm water runoff in the area. However, tarp usage to collect spills 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. Waste Discharge Requirements Order No. 97-042 (NPDES No. CA0084077) was 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. Material and product handled at the Port which is spilled directly to surface water is considered a non-storm water discharge. Discharge Prohibition A.5. 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." California Environmental Protection Agency Ca Recycled Paper