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Ms. Wendy Wyels <br /> Re: Koppel Stockton Terminal <br /> May 2, 1995 <br /> Page 2 <br /> Munco never denied that nitrates were on the property in the form of <br /> fertilizer. The RWQCB's testing on March 6, 1995, only confirmed that there <br /> was fertilizer in the building and near the loading area. This confirmation <br /> does not in and of itself establish that groundwater over fourteen feet below <br /> the surface is impacted. Because Munco is concerned that scraping the surface <br /> soil does not draw an accurate picture, Munco proposes to conduct a limited <br /> soil investigation of the soil at depths to six feet below the exact locations of <br /> the elevated nitrate surface samples. A workplan is enclosed as attachment <br /> "B" for your review and approval. <br /> just to give you a little background on this site, Munco, Inc. <br /> (hereinafter "Munco") purchased the property in December 1985. Munco <br /> assumed the duties of warehousemen at the site for its two main tenants, <br /> Chevron and Cargill, Inc. This warehouse was used for storage of bulk <br /> fertilizer. During the three years Munco owned the property, liquid fertilizer <br /> was never stored on the property, nor was fertilizer ever mixed or made on <br /> the property. There is no evidence to indicate that Munco employed poor <br /> environmental practices that may have contributed to any potential <br /> discharge. In fact, Munco prides itself on its careful and environmentally <br /> sound operation of the storage facility. <br /> Munco purchased the property in December 1985 from Koppel <br /> Stockton Terminals, Inc. (hereinafter "Koppel") who was the owner and the <br /> operator of the warehouse until December 1985. It is our belief that Koppel <br /> Stockton Terminals, Inc. stored only solid fertilizer. The only evidence of <br /> environmental damage or poor environmental practices -- the three Notices <br /> of Violation (hereinafter "NOV") issued in the late 1970s and early 1980s -- <br /> relate solely to the operations by Koppel. The NOVs formed the basis for the <br /> RWQCB's request of Munco for a site investigation workplan. Therefore, the <br /> RWQCB should look to Koppel as the primarily responsible party for any <br /> potential discharge. <br /> In 1989, Munco sold the property to the Munzer Family Trust <br /> (hereinafter "Trust"). The Trust leased the property to Cargill, Inc. <br /> (hereinafter "Cargill"). Cargill operated the warehouse and continued using <br /> it for bulk fertilizer storage. The Trust never operated the warehouse. In <br />