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t CG~O[L'.CC GcPiu~:?I°?i'i VF ii%~1LT1{, Water Quality Control Division Renawai 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 material, 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 Che 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 e:cposure 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 Co coordinate these activities with any necessary new activities in an orderly manner so chat 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 the air or hazardous waste disposal sites. In fact, the permittee is encouraged to srrive for tkiis overall goal. Where the reduction of water pollution only results in the increased pollution of ocher media, there is no net benefit to the environment. The permittees certified under this permit shall be required co submit a SWMP to the Division for review within six months from the date Che 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 Cimely execution of these controls. Where construction is necessary, the plan shall include a sc!tedule detailing the milestones involved with such construction. As necessary, elements of the plan may require prior approval from Che CMIRD. The plan shall include a statement signed by cop management in which they affirm that compliance with Che plan shall occur. Also, it shall provide for updates where there is a change in operation chat will or may result in a change in Che quality of pollutants addressed by this plan, or if [he 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 GDPS permit. The permittee will be expected to certify on a yearly basis chaC the plan is being implemented as required.