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COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division Rationale - Page 25. Permit No. CO-0027154 VI. TERMS AND CONDITIONS OF PERMIT (continued) Office Code Event 90508 Materials Containment Plan Update 25099 Salinity Report 05899 Stormwater Management Plan Submittal 59499 Stormwater Management Plan Implementation 90199 Stormwater Management Plan Annual Reports Permit Citation Due Date Part I.F.1. 90 days after effective date Part I.A.4. October 1, 1993 Part I.C.3.b July 1, 1993 Part I.C.3.b December 14, 1993 Part I.C.6. First Report is due November 28, 1994 2. Thirty Day Avera¢e: The permittee should note that the definition for a thirty day average has changed. Please review footnote J on page 2 of the permit. Jon C. Kubic August 3, 1992 VII. PUBLIC NOTICE COMMENTS Permittee Comments -- The permittee submitted comments accompanied by substantial documentation. They also met with the Division to discuss their concerns. The general topics are: flow limitations, silver limitations and the hardness value used in computation of TVS metals standards for outfalls 001, 005 and 007. Flow Limitations: The permittee questioned the need for flow limitations for outfalls 001, 005 and 007. They are correct in this instance. Although the metals limitations were calculated using a mass balance formula that includes the effluent flow, this flow volume has no influence because the low flow is zero. The resulting metals effluent limitations are equal to the standards, regardless of the facility flow. On this basis, the flow limitations ate being dropped from outfalls 001, 005 and 007. Monitoring will be required. Silver Limitations: The permittee questioned the need for silver limitations for outfa11s.001, 005 and 007 in this renewal permit on the basis that effluent levels have been and remain well below the applicable limitations. Outfalls 001 and 007 did not have silver limitations in the previous permit. The decision to not include limitations in that permit was based on a comparison with a one- time analysis. Because silver monitoring was not required for outfalls 001 and 007, the Division had no more recent silver data on file for these two outfalls. Thus, in lieu of data, silver limitations were imposed for outfalls 001 and 007. Silver limitations were included for outfall 005 as a continuation of the previous permit. '