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COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division <br />Rationale -Page 8. Permit No. COGSC0000 <br />V. TERMS AND CONOTTIONS OF PERMIT <br />D. Public No[ice Chanties <br />Fire rommem letters were renivrd by the Division during the 30 day public romment period Several clarifications <br />and changer were made to the drafr permit based on these commerus. <br />Several commenters expressed roncern with the nerd to submit a ropy of the SWMP to the CDMG. A major <br />concern war that other stater and EPA regions were not requiring submittal of the plans. <br />In reviewing the issue, the Division concluded that, jot facilities mined under the Sand and Grare! general <br />permit, plan derelopmeru and implaneruation is still nenssary, but submittal would only be required upon <br />specific written request by the Division or CDMG. One major benefit of this approach is that Division and <br />CDMG resources can be better utilized in ronducting field inspections and checking program implementation. <br />The information rollected wi11 then allow proper program adjustmems at permit renewal (in fist years). <br />Coordirwtion with CDMG will be through the due date of certification that the SWMP has been prepared and <br />implemented, which is based on the due date jot the jaciliry's annual reclamation permit report to COMG <br />during July l , 1993 to June 30, 1994. It is assumed that SWMP preparation may generate the need for <br />teehniro! revisions to the facility's reclamation permit through CDMG, and so the SWMP cert frcafion due <br />dates art spread throughout the year to stagger tlu COMG's workload. <br />For any facilities mrered under this permit which do not also have a reclamation permit under GDMG, the <br />SWMP cent fication of mmpktion and implememation is due by July 1, 1993. <br />2. One mmmemtr requested the removal of the annual reporting reguiremens jot stormwater discharge. Given <br />that submittal of the SWMP it no longer automatic, the Division believes that the best ovrraU method of <br />determining romplianee by the regulated rommuniry, without imposing stormwatn monitoring requirements, is <br />submittal ojan annual repots. The reporting requiremens bare been scaled back to reflect the fact that the <br />Division will not have a copy of the SWMP on hand ~n mast cases). <br />/n addition, the permit has been clarified to show that no annual reports will be due before February IS, <br />1994. The permittee's certification will indicate Jhe eruct due date jot the first annual report. <br />3. In response to many romments from the ronstruction and mining rommuniry, this permit coinage hat been <br />broadened to include mnoete batch plants. Process water discharger from roncrete batch plants (including <br />truck wash water) will be subject to the numeric limits at listed in Section V.A.I.a ojthe Rationale. <br />4. More derail hat been added to the romprehensire inspection requiremems, jot consistency with the Division's <br />other stormwater general permits. <br />There were several other rommerus received by the Division on this permit. The issue raised have been addressed in <br />individual letters ra the commemers. This permit is subject to renewal in September, 1997. At that time, appropriate <br />changes will 6e made in the permit to reflect the additional knowledge and experience gained in the imerim. <br />Kathryn Dolan <br />August 24, 1991 <br />