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COLORADO DEPARTMENT OF HEALTH, Water Qualih~ Control Division <br />Rationale -Page 26 Permit No. CO-0045675 <br />- Assessment ojan instream point of compliance <br />VI//. CHANGES TO PERMIT AND RAT/ONALE FOLLOWING PUBLIC NOT/CE <br />Pab[ic Notice Period, Comment Letters and Pablic Meeting: (Cont.): <br />Responses to Comment Letters: (Con[.) <br />Comment: Issues Relating to the Impac[ to the Rito Seco/Surface Waters/Downstremn: (Cont.) <br />Responses: <br />The proposed CDPS discharge permit will be protective ojthe classified uses (for recreation, aqua[ic life, agriculture, and drinking <br />xater uses) and the ~+ater quality standards r/mt exist for the Rim Seco. /n fact, due to the antidegradalion-based limits, dte permit <br />xill be generally much more protective x~ith restrictive limits drat are often much lower than the water quality smndards and/or <br />drinA~ng water MCL values. Appendix C shows a comparison betx~een the antidegradatiom-based [intits and the water quality <br />standard-based limits jor outfa[l OOIb. <br />With attainment of antidegradation-based limitations and x•a[er quality standard-based limitations and prevention of discharges at <br />002 from the West Pit in this CDPS permit, [here will be no adverse impacts to existing Watershed projects in the area. Also, this <br />should ewble a centering of attention to other projec[s in the area which x~ould be more critical to address. <br />Specific issues relating to surface water quality are funkier discussed in Appendtz D. <br />Comment: Other Issues: <br />- Recommendations that the BMR! stormxater discharge permit should be reevaluated <br />- Submittal ojdiscltarge monitoring report data to additional entities <br />Responses: <br />Stormwater: The current draft of the CDPS permit was developed in support ojlhe currently active irnp[ementation of reclamation <br />and remediation activities in the West Pit. BMR/ currently holds a stonmvater penmit and has met all ojthe reporting requirements <br />of the stonnwater permit. stonnwater is not part of the application for this CDPS permit currently under consideration by the <br />CDPHE. WQCD stajj'have reviewed the stonnwater management plan submitted by BMR/ jor [heir existing general stonnwater <br />permit. <br />Discharge Monitoring Report Submission: The Division does nor require perntittees to submit extra copies of discharge monitoring <br />reports (DMRs) to additional entities other t/tan [o the Division and EPA. However, BMRI has indicated that they are willing to <br />submit an additional copy of the DMRs to a local entity. San Luis Water and Sanitation Distric[. <br />Don Holmer <br />August /, 2000 <br />