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COLORADO DEPARTMENT OF •, Water Quality Control Division • <br />Rationale -Page 13, Permit No. CO-0029947 <br />D. Addilinnal Tcrms and Conditions (Corr.) <br />3. Leak Detection Svstem Monttorine - The facility will continue to be required to perform weekly inspections of the <br />evaporation pond leak control and detection system Vault for the presence of retort xnter leakage. If any retort <br />or dibued soon water is present, Oiaidental Oil Shale, Inc. will be required to notify the Division in an <br />attaclunent ro the discharge monitoring report. The aaachmrnt shoo spee(fy xiar oorretxion has been employed <br />!ry the facility to identify and hak the cause of du leakage. Water aantainen' within the watrlt shall be monuared <br />for total mnnwnia, COD, fluoride, oil & grease, and phenols. Results of such monitoring shall accompany the <br />attachment to r/tc discharge monitoring report. Refer to Parr L E.3 of the permit. <br />4. Groundwater Manitorine and Notifuation of Channe - Although t)u facility is in a suspended mode of operation, <br />a groundwater monitoring program may be required to address any potential releases from the process watts <br />containment facilities if retorting and/or other process operations resume within the duration of this renewal <br />permit. 71te facility is required to notify the Division of process changes as listed in Part ILA.1 of the permit. <br />Also, sce Pan I. E.4 of the prrnut. <br />E. Waste Minirniratior/PoUution Prevention <br />Waste minimization and pollution prnrntion are Mn turns that arc bxoming increasingly more common in <br />industry today. Waste minintiZation includes reducing the amount of waste at thee source through changes in <br />industrial processes, and reuse and rerycling of xttstes for the original or some other purpose such err materials <br />recovery or energy production. Pollution prevention goes hand-in-hand with xnste minirntzation. Ijthe xnrte is <br />eliminated at the front of the lute, it will not have to be trtatad at the end of the line. 71te direct beneftts to the <br />industry are often signifu;am -both in terms of increased profu and in public relations. <br />This program can affect all areas of process and wnsu control with which an induustry deals. Elimination or <br />reduction of a xnstewstter polluant can also result in a reduction of an air pollutant or a reduction in the amount <br />of hazardous materials which must be handled or disposed. <br />This discharge permit does not spccificaUy dictate wttste minimization conditions at this time. The Division <br />strongly encourages the permittee to develop a x~zste minimization plan. Several industries have already developed <br />plans and found that implementation rauhed in substantial savings. Both the Colorado Department of Health and <br />EPA have information and resources available. -• <br />Wesley N. Gamer <br />Science Applications Imernational Corporation <br />June 14, 1994 <br />V//. PURL/C NOTICE COMMENTS <br />