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California P*ional Water Quality Isontrol Board Central Valley Region Robert Schneider,Chair a Sacramento Main Office Winston H.Hickox Internet Address: http://www.swreb.ca.gov/—mgcb5 Gray Davis Secretaryfor 3443 Routier Road,Suite A,Sacramento,California 95827-3003 Governor Environmental Phone(916)255-3000•FAX(916)255-3015 Protection 7 May 2001 VIA FACSIMILE Mr. Mike Bowles Pilkington North America 500 East Louise Avenue Lathrop, CA 95330 TRANSMITTAL OF LATE REVISIONS OF WASTE DISCHARGE REQUIREMENTS, PILKINGTON NOR TH AMERICA, LATHROP, SAN JOA Q UIN CO UNTY I am transmitting the Late Revisions for the revised tentative Waste Discharge Requirements (WDRs) for the Pilkington North America facility in Lathrop. The Late Revisions address Pilkington's 24 April 2001 comments about the revised tentative WDRs. Many of your comments were addressed. Some issues are not consistent with the Board's procedures and therefore were not included in the Late Revisions. Those issues are addressed below; portions of Pilkington's comments which were not addressed are presented in bold italic text. As indicated in its letter of March 30, 1001, Pilkington wishes to maintain its current NPDESpermit and its application for renewal as submitted on June 30, 1995, until such time as conditions of the new Waste Discharge Permit are determined to be reasonable and feasible for conducting normal business practice at the facility. Pilkington has continued to maintain this permit despite its lack of discharge to the San Joaquin River because of the on-going uncertainty regarding its ability to consistently discharge to land under all conditions. Its application for renewal has never been acted upon by the Board and Pilkington has continued to hold the permit and pay all applicable fees associated with its maintenance, all with the knowledge and apparent acceptance by the Board. As such, Pilkington believes that the permit is still in force until such time as it voluntarily releases it to the Board or until such time as the Board denies Pilkington's application for renewal. At the point in time that Pilkington is satisfied it can comply with all requirements of the revised WDR, it will be pleased to surrender its permit. Allowing two permits to exist for the same discharge is not consistent with Board procedure. It is noted that the National Pollutant Discharge Elimination System(NPDES) Permit No. CA0004839, WDR No. 91-056, expired on 1 February 1996. Review of Pilkington's application was delayed because of staffing limitations at the Regional Board. Pilkington states that it desires to keep the NPDES permit active until such time that land discharge can be determined to be feasible under all conditions; it is noted that Pilkington has not discharged to surface water since the early 1990's. This fact is evidence that land discharge is feasible and practicable. The tentative WDRs scheduled for a public hearing on 11 May 2001 are consistent with Pilkington's discharge methodology with improvements required to better protect groundwater quality,prevent surface runoff, distribute wastewater on land application areas, and provide public notice of the wastewater application. A schedule for the improvements to be California Environmental Protection Agency Oa Recycled Paper The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. For a list of simple ways you can reduce demand and cut your energy costs,see our Web-site at http://www.swrcb.ca.gov/rwgcb5