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COLORADO DEPARTMENT OF ! • ,Water Quality Couro[ Division • Rationale -Page Jl, Permit No. CO-0029947 4. StormwatcrEvaluation: (Cou.J The Division received a letter datrd June 17, 1994, fran Dames and Moore for the Accidental Oil Shale, Inc., Logan Wash mine site project. Tlds letter stated that there have been no leaks or spilis of a reportable quantity ar nc~ site. In addition, from fold evaluations made at the sac, thty daernuned that stormsHater does not come into contaeY with any process stnstes. Based on this inforrttation, an appUcation for a stornnwttr discharge permit has not been required Refer to this letter fintn the Division (dined 5-2-94 and 622-94J jot additional detaiis related to stormwater at this facility. ~J'laterfound to be needed, storm ter perniitting issurs jot rJds facility will be handled separately by the Division's Stormwater Unit, although this pemut may be reopened at a later dare to incorporate srormunter provisions, ijdeemed appropriate. S. Economic Reasonableness Emhuuion: SaYion 25~-503(8) of the revised (June 198SJ Colorado Auer Quality Control Act required the Division to detnmine wi~aher or not any or all of the ssnrn quality standmd based e_Qlueu limitations arc reasonably related to the economic, envirounental, Public health and energy impacu to the public and affected persons, and are in furtherance of tht policies set forth in sections 25~-192 and 25-8-104. The Regulations for the State Discharge Permit System, 6.1.0, fwther define this requirement under 6.12.0 and state: 'Where tonomic, environmental, Public health and energy impacts to the public and affected persons have been considered in the classifications and standards sitting process, ptrmixs written to med the standards may be presumed to have taken iuo consideration economic factors unless: a. Anew permit is issued where the discharge was not in existence at the time of the classification and standards rdemaldng, or b. In the case of a continuing discharge, additional information orfactors have mterged that were nor anticipated or considered u the time of the classification and standards rulemaking. " The evaluation jot this permit shows than the Water Quality Couro! Commission, during their prareedings to adopt the Class fkation and Numeric Standards for the Lower Colorado River Basin, rnnsidered economic reasonableness. Furthermore, this is not a new dischargtr artd no new information has been preseued regarding the class fuations and standards. Therefore, the inter quality standard-based ejJlttcnt limitations of this permit arc determined to be reasonably related to the economic, environnunral, public health and energy impacts to the public and affected persons and are in furtheronce of tht policies set forth in Sections 15-8-102 and 104. If the permittee disagrees with this fading, pursuau to 6.12.0(2)(6) the pnmittee should submit aU pertineu information to the Divirian during the public notice period. B. Monitoring 1. Effluent Monitorin¢ - Due to the compliance history with tht previous permit limits and the curreu maintenance only mode of the facility, there is adequate justification that the monitoring requirements from rite previous permit are sufftcieu to ensure compliance with the permit limitations for this facility. Therefore, the monitoring frequencies for each outfall are unchangtd from the previous ptrmit except for WET testing which has been incorporued iuo the Table V/-4.