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Ms . Wendy Wyels <br /> February 21 , 1995 <br /> Page 2 <br /> primarily liable, the RWQCB should unequivocally be pursuing <br /> the former owner and operator of the Koppel Stockton <br /> Terminal. <br /> Second, the mere existence of fertilizers on the site <br /> does not mean that there is soil and groundwater <br /> contamination. To say that every industrial property is <br /> contaminated is overbroad. Also, please note that liquid <br /> fertilizer was not handled on this site at any time after <br /> MUNCO purchased the property. The tank you mentioned in <br /> your letter was used strictly as a water tank. No liquid <br /> fertilizers were stored on site. <br /> Third, in your letter you mentioned that at a site in <br /> the Sacramento area, you " feel that any level over 250 ppm <br /> nitrogen may impact water quality, " yet, then you set the <br /> threshold for this site at 200 ppm total nitrogen. It is <br /> our opinion that the RWQCB needs to be consistent; <br /> therefore, the threshold for further investigation and <br /> testing at the Koppel Stockton Terminal should be 250 ppm <br /> total nitrogen. <br /> As stated before, our client desires to cooperate with <br /> the Regional Board. Therefore, the Regional Board will be <br /> permitted entry on to the property for the purpose of <br /> collecting soil samples from around the load-in and load-out <br /> areas , and water samples from the pond, and if necessary a <br /> groundwater sample. Our client desires to have his <br /> consultant, Roy F. Weston, Inc . , present during the <br /> sampling. In addition, we hereby request that the Regional <br /> Board split the samples so that Roy F . Weston, Inc . can <br /> likewise analyze the samples. Entry onto the property is <br /> conditioned upon the above two requests . <br /> Please schedule the testing with Paul Sundberg at <br /> Weston (209) 476-1635 . As always , should you have any <br /> questions or comments , please do not hesitate to call. <br /> Sincer ly yours , 0 <br /> 07 f <br /> S. GOLDBERG <br /> Attorney at Law <br /> LSG:ect <br /> cc: Ms. Diane Hinson <br /> Mr. Dan Munzer <br /> Mr. Paul Sundberg <br /> 28722-1 <br />