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t33'ATE OF CALIFORNIA - Environmental Protection Agency PETE WILSON Governor CALIFORNIA REGIONAL WATER QUALITY CONTROL ' fMEfJT y 'a — CENTRAL VALLEY REGION P It Al HEQ�jy R. ,IT cC ;_ 3443 Routier Road, Suite A - •.FRVICE app .r,,�i Sacramento, CA 95827-3098 �� PHONE: (916) 255-3000 •`a,8,._�,,.^" FAX: (916) 255-3015 $f�$ 's PN 1: 25 Y 6 February 1995 Ms. Leah S. Goldberg Neumiller & Beardslee 509 W. Weber Ave. Stockton, CA 95203-3166 KOPPEL STOCKTON TERMINAL - On 29 August 1994, Board staff requested the owners of the Koppel Stockton Terminal (at 2025 W. Hazelton, Stockton) to submit a workplan to determine whether they are the source of the elevated nitrate levels in nearby groundwater. Our justification for this request was based on our review of permits and violation notices obtained from San Joaquin County. Your 28 December letter states that a 1992 Notice of Violation was issued to a contractor who was cleaning the building, and that this does not support the request for an investigation. While staff agree that the 1992 violation is ambiguous, we still feel justified in asking for an investigation. The reasons are: s :s 1. The San Joaquin County Air Pollution District issued three Notices of Violation in 1977 and one in 1981 to the property at 2205 W. Hazelton. These violations were for visible emissions while top-loading trucks. The 1981 violation states that the trucks were being loaded with ammonium nitrate. (Copies of the violations are enclosed). 2. Air permits were issued to the Koppel Stockton Terminal for bulk receiving and bagging of chemical fertilizers, for railcar reconveyance of ammonium nitrate, and for bulk material receiving and storage of urea. (Copies of these permits are enclosed). Ammonium nitrate is a solid fertilizer, while urea is handled as both a solid and liquid fertilizer. 3. In 1992, the County received a request to transfer the above permits from Cargill Fertilizer Division to Sprekles Sugar (also enclosed). 4. The Koppel facility contains several stations from which fertilizer may be unloaded from railroad cars and stored in the warehouse. There are also several outside stations from which trucks may be loaded with the material contained in the warehouse. There is also a large (about 50,000 gallon) above ground tank next to the warehouse. This tank may have been used to convert solid urea to liquid. The tank also contains a load-out area. - 5. Staff are involved in cleanups at several dozen sites at which fertilizer was reconveyed, stored, and/or loaded. Our experience shows that small spills of fertilizer, repeated over many years, has the potential to impact groundwater. For example, the soils at a fertilizer railcar unloading area in the Northern Sacramento Valley contain up to 20,000 ppm nitrogen.