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CLEANUP AND ABATEMENT OR. .R NO R5-2008-0707 -2- MARTIN OPERATING PARTNERSHIP AND THE PORT OF STOCKTON MOLTEN SULFUR PROCESSING PLANT SAN JOAQUIN COUNTY Prill transport from the stockpiles to the docks is performed via an aboveground conveyor system. This conveyor system is owned and operated by others. The prevailing winds are from the west and northwest. The facility retains process water, leachate, and stormwater on site for reuse as quenching water in the prilling process. Due to acidic conditions caused by the contact of sulfur with water, the process water and leachate are pH-adjusted prior to reuse. The plant consumes 37,888 cubic feet (283,422 gallons) of water per month; a portion of which is obtained from stored rainwater and recycled/neutralized leachate. Water/leachate is contained in Hypalon-lined ponds or the AST located at the southern portion of the site, as shown on Attachment B. 8. The Discharger is enrolled under the State-Wide General Permit for Industrial Storm Water No. 97-03DWQ. The facility is not regulated by any waste discharge requirements. IMPACTS TO GROUNDWATER AND SURFACE WATER The prill stockpiles are located outside and are exposed to precipitation during storm events. In addition, the piles contain some moisture after processing. After water contacts and interacts with the prill, an acidic leachate is formed that flows through a below grade system to a below grade chamber and sump. The leachate has a low pH, and high concentrations of sulfur, sulfate, specific conductance, and total dissolved solids (TDS). This leachate is collected and routed to on-site water treatment equipment where leachate is neutralized and then transported to the AST for eventual reuse in the prilling process. During transfer to the wharf, sulfur may drift or spill from the conveyor system onto the earth. During storm events an acidic leachate is generated where stormwater contacts the prill on bare earth. At the October 2004 Regional Water Board meeting, the Regional Water Board requested that staff inspect the Discharger's facility and determine if the facility is degrading waters of the state or if the facility poses a threat to water quality. On 30 March 2005, staff inspected the facility, obtained field samples, and recorded observations. Staff noted ponded water in contact with sulfur piles within the stockpile area; sulfur on bare earth in contact with ponded rainwater; and evidence of sulfur in storm ditches and sumps (i.e., high concentrations of electrical conductivity and a low pH). The field sample results had the following concentrations: