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1 C ' ~ L COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division Renewal Permit Rationale - Page 2. Permit No.: COG-850000. II. Permit Changes (continued) BMP's also include treatment requirements, operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or drainage from raw ma[erial, intermediate and finished product storage. Pollution prevention (incorporating waste minimization) is an essential part of best management practices. The permittee must look at all phases of the operation to determine what changes could be made that would result in a lower consumption and/or disposal of pollution-generating materials, as well as minimizing exposure of pollutants to stormwater. Such efforts often result in greater profit to the permittee and less pollution of the environment. The mechanism for implementation of stormwater BMP requirements within this permit shall be the stormwater Management Plan (SWMP). The permittee will be required to develop and implement a SWMP plan. Some activities required under this plan may already be in place. However, the SWMP plan will require the permittee to coordinate these activities with any necessary new activities in an orderly manner so that the result is the reduction or elimination of pollutants reaching state waters from areas rot limited by effluent limitations. An added benefit may be a reduction of pollution reaching other media, such as th_ air or hazardous waste disposal sites. In fact, the permittee is encouraged to strive for this overall goal. Where the reduction of water pollution only results in the increased pollution of other media, there is no net benefit to the environment. The permittees certified under this permit shall be required to submit a SWMP to the Division for review withir_ six months from the date the certification is issued. The requirements of the plan do not specify the exact pollution control facilities that the permittee must construct. Instead, the plan allows for creativity on the permittee's part, as long as the goal is achieved. Each permittee will need to determine what controls are necessary at the specific site. Then, the permittee will need to develop a plan for the timely execution of these controls. Where construction is necessary, the plan shall include a schedule detailing the milestones involved with such construction. As necessary, elements of the plan may require prior approval from the CMLRD. The plan shall include a statement signed by top management in which Chey affirm that compliance with the plan shall occur. Also, it shall provide for updates where there is a change in operation that will or may result in a change in the quality of pollutants addressed by this plan, or if the plan is shown to be ineffective in achieving the specified goals. The plan, once submitted, will be incorporated into the permit and its implementation will be considered a permit requirement. Failure to do so could result in enforcement action. The plan shall remain in effect as long as the facility is regulated by a CDPS permit. The permittee will be expected to certify on a yearly basis that the plan is being implemented as required.