THIS ACTION CONCERNS CLEAN WATER ACT VIOLA- TIONS BY THE STOCKTON PORT DISTRICT (PORT). THIS ACTION IS FOR INJUNCTIVE RELIEF TO PRE- VENT THE PORT FROM DISCHARGING FERTILIZER OR OTHER POLLU- TANTS INTO THE STOCKTON SHIP CHANNEL DURING SHIP UNLOADING OPERATIONS. ADDITIONALLY, CIVILPENALTIES OF TEN THOUSAND DOLLARS PER DAY FOR DOCUMENTED VIOLATIONS ARE CLAIMED. THIS ACTION IS BEING PURSUED AS A DETERENT TO LAX OPERATING PROCEDURES OF THE PORT DURING TRANSFER OPERA- TIONS AND TO ENGENDER A SENCE OF RESPONSIBILITY TO IMPLEMENT ENVIRONMENTAL CONTROL MEASURES. THE PORT, DURING SHIP TO SHORE FERTILIZER UNLOADING OPERATIONS, USES EQUIPMENT THAT TENDS TO CONTINUOUSLY DISCHARGE QUANTITIES OF FERTILIZER INTO THE SHIPPING CHANNEL. THIS DISCHARGE COULD BE SUBSTANTIALLY MITIGATED BY INSTALLING A APRON-LIKE DEVICE BETWEEN THE SHIP AND THE DOCK WHEN TRANSFERRING MATERIAL. THE STOCKTON SHIP CHANNEL IS A LOCATION OF HIGH ALGAE BLOOMS. THE AMOUNT OF FERTILIZER LOST DURING THE TRANSFER OPERATION MAY BE MINIMAL IN TERMS OF THE TOTAL AMOUNT TRANSFERRED; HOWEVER, THE NITROGEN CONTENT COULD IN REALITY AGGRAVATE THE SERIOUS ALGAL WATER POLLUTION PROBLEM THAT NOW EXISTS IN THE AREA.