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viii CALIFORNIA REGIONP WATER QUALITY CONTROL BOARD CENTRAL VALLEY RE )14 3443 Routier Road, Suite A Sacramento, CA 95827-3098 Phone (916) 255-3000 FAX (916) 255-3015 97 OCT -5 t,M 8: 3 7 f^-14/1111171/EPA Pete Wilson, Goverror 30 September 1997 Mr. R. G. Bloom The Devco Companies 5314 S. Yale, Suite 770 Tulsa, OK 74135-6252 BAY SULFUR COMPANY, SAN JOAQUIN COUNTY (Case No. 3929) We have reviewed the 24 September 1997 letter from Kleinfelder with the design details from your office. We concur with your proposal to modify the facility's drainage controls to separate storm water runoff from the sulfur processing and storage areas from the remainder of the site's runoff. We also concur with your plan to construct the above-ground "neutralized water tank" to hold treated runoff and process water from your plant. However, the tank design should be changed to include a drainage layer such as a geosynthetic drainage net between the two liners. This addition will help ensure early detection of leaks in the upper liner and minimize head buildup on the lower liner. We understand that you intend to keep the two lined ponds at the facility. The ponds are shown in the design drawings as the runoff water tank and the secondary run-offtank. Storm water runoff outside of the sulfur processing and storage areas will flow to these structures. Water from these ponds will either be used for make-up water in the plant or discharged off-site in compliance with the NPDES General Storm Water Permit. The ponds will also serve as emergency containment in the event the neutralized water tank overflows. This water will be pumped back to the neutralized water tank as soon as capacity is available. Please note that the off-site discharge of industrial process water or storm water mixed with process water is not covered by the General Storm Water Permit. In the event water from the neutralized water tank overflows into the ponds, it must be contained and recycled back into the plant. Any discharge of this water to surface water is prohibited unless you obtain an NPDES permit written specifically for such a discharge. Given the sporadic and temporary use of the ponds for emergency containment of treated wastewater, we do not view the proposed operation of the ponds as a threat to water quality. Therefore, we do not intend to regulate the ponds under Title 27 (formerly Chapter 15) and we will dismiss your pending report of waste discharge once the neutralized water tank is built. T; Recycled Paper Our mission is to preserve and enhance the quality of California's water resources, and ensure their proper allocation and efficient use for the benefit of present and future generations.