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KOPPEL STOCKTON TERMINAL <br /> For that particular site, we feel that any level over 250 ppm nitrogen may impact water <br /> quality. At every load-in and load-out station at the Koppel facility, there is the potential for <br /> spills of fertilizer into soils. <br /> 6. A portion of the stormwater from the Koppel site appears to flow north, where it is trapped <br /> by converging railroad tracks, and forms a pond. It is very possible that rainwater has picked <br /> up spilled fertilizer and carried it to the pond. The nitrate would then solubilize and could <br /> easily enter the shallow groundwater. <br /> Based on the above, staff continue to consider the Koppel Stockton Terminal as a potential source of <br /> the nitrate found in the groundwater downgradient of the site. While we do not know whether <br /> Munco owned this property at the time the County permits and violations were issued, there is <br /> substantial legal precedent for naming the current property owner as a "Discharger" and requiring <br /> him to conduct a site investigation and/or cleanup. <br /> Your letter states that your client wishes to cooperate with the Regional Board. To that end, we are <br /> willing to conduct an informal assessment of the facility. Board staff would collect soil samples <br /> from around the load-in and load-out areas, and a water sample from the pond. If possible, we <br /> would also collect a groundwater sample. We would use our own laboratory funds to analyze the <br /> samples for total nitrogen. If the soils contain less than 200 ppm total nitrogen, and the water less <br /> than 45 ppm nitrate, we would no longer be concerned. However, if elevated levels are found, then <br /> Munco would be required to complete a full assessment. <br /> F <br /> If you wish to accept our offer to conduct an informal assessment, please contact me by <br /> 28 February. If you do not wish to work cooperatively, we will proceed to prepare an enforcement <br /> order. If you have any questions, I can be reached at (916) 255-3104. <br /> WENDY WYELS <br /> Ag Regulatory Unit <br /> cc: Mr. Rudolph Munzer, Munco, Long Beach <br /> Ms. Diane Hinson, San Joaquin County Public Health, Stockton <br />