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Mr. Alexander Krygsman - 2 - 21 September 1998 Effluent Limitation B.2. states: "The Discharger shall reduce or eliminate the discharge of pollutants in non-storm water discharges identified in Provision D.9 from facilities operated by the Discharger through implementation of BAT and BCT technologies." Provision D.9.c. covers discharge of material associated with loading and unloading activities by the Discharger, and states: "The Discharger shall implement BMPs forthwith that reflect BAT and BCT technologies to prevent or minimize the direct discharge of materials associated with shipping, receiving and storage activities." "The Discharger shall evaluate the effectiveness of the BMPs implemented and shall revise, amend, or add BMPs if the Discharger determines the BMPs are not effective, or at the request of the Executive Officer." In accordance with Waste Discharge Requirements, Order No. 97-042, you are requested to implement BMPs that reflect BAT and BCT technologies to prevent spills of product from the conveyor and ship loader to the ground, dock, and receiving water, and sulfur dust emissions from the ship loader. On 2 September 1998, our staffs met to discuss ship loading modifications you are currently implementing. Your letter of 14 September 1998 also provided information regarding those modifications. ]Ry 15 October 1998, please submit your plans and a time schedule to complete the proposed upgrades to the conveyor to prevent spillage and dust emissions, as well as all BMPs which will be implemented in the short-term for each loading event to minimize spills, capture what cannot be contained, and-to clean up residues without discharging to the receiving water. The report must also detail an effectiveness monitoring program to demonstrate measured improvement from the modifications. Finally, the report must address long-term plans to upgrade the loading operation so that reliance on operational controls such as tarps can be eliminated. Finally, we have determined that the sulfur conveyor and other transportation facilities at the Port with operations associated with industrial activity, as defined in the General Industrial Permit need to be included in the Port's Industrial Permit. The Port must amend its Notice of Intent, Storm Water Pollution Prevention Plan, and Industrial Permit Monitoring Program forthwith to include these operations. Please contact Patricia Leary at (916) 255-3023 if you have any questions. GY . CARLTON Executive Officer Enclosure