NEC Art. 250.4 General Requirements for Grounding and Bonding. (B) Ungrounded Systems. (2) Bonding of Electrical Equipment.:
"...shall be connected together and to the supply system grounded equipment in a manner that creates a low-impedance path for ground-fault current that is capable of carrying the maximum fault current likely to be imposed on it."
Art. 250.24 Grounding Service-Supplied Alternating-Current Systems. (C) Grounded Conductor Brought to Service Equipment. (3) Delta Connected Service.: “The grounded conductor of a 3-phase, 3-wire delta service shall have an ampacity not less than that of the ungrounded conductors.”
That means-in my opinion- in any case the 4th conductor could be the grounding bonding wire. It has to be the same cross section area as live conductors and has to be grounded both ends.