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<br /> <br />COLORADO DEPARTuENT OF HEALTH <br />Water Ouallty Control Division <br />Rationale - Page 5 <br />Permit No. CO-0035653 <br />DISCUSSION: <br /> <br />A. Total Suspended Solids - E.P.A. promulgated final BAT regulations on <br />October 19, 1985, but BCT (Best Conventional Pollutant Control <br />Technology) Ss being reserved pending finalization of EPA's BCT cost <br />methodology. Therefore, BPT shall apply. The SES limitation is not <br />applicable pursuant to Section 10.1.3(3) of the State Regulations for <br />Effluent Limitations, which states that when EPA has effluent <br />limitations for an Sndustry, the federal limitations shall take <br />precedence. <br />B. Alternate Limitations - As indicated in other sections of the <br />.rat ono e, some a uent limitations are or are not effective, <br />dependent on occurrences of precipitation. Pages la, lb and lc of <br />the permit indicate when specific limitations apply. In order for <br />the permittee to claim a "storm ezemption" from the total suspended <br />solids and total iron limitations, documentation of the eligible <br />storm event must be submitted to the Division along with [he <br />appropriate discharge monitoring report (DMR). <br />C. Materials Containment Plan - Pages 6 and 7 of the permit describe the <br />Materials Containment Plan (MCP) which is a requirement of all <br />permitteea. If a Spill Prevention Control and Countermeasure (SPCC) <br />Plan hoe already been submitted by the permlttee and approved by the <br />Division, submittal of an annual update to this plan will satisfy the <br />MCP requirement. <br />D. Reopener Clause -This permit may be reopened and modified as <br />discussed In Part II.B.S if there !a a sign iflcant change in state or <br />federal water quality regulations, a sign iflcant change Sn operation <br />at the facility, or at the request of the permittee. <br />Public Notice Comments: <br />1Thile the permit was at public notice, the division became aware of a spoils <br />water seep near the base of pit 5 (a reclaimed area). The discharge from the <br />seep 1s intermittent and of very low volume when discharging. Samples show <br />the discharge is of very poor quality (iron in the 10 to 15 mg/1 range). The <br />division feels that little impact can result at this time from this discharge <br />} and, for this reason will not currently impose additional permit conditions. <br />{ But, the permittee has been advised to visually monitor the discharge and <br />notify the division if volumes increase or other factors change which may <br />~ impact state waters. <br />Jon C. Kubic <br />October 23, 1985 <br />