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COLOR~IDO DEPARTMENT OF HEA1.T71, Water Quality Comrol Division <br />Rationale -Page 8. Permit No. COG-SOOpA7 . <br />V. TERMS AND CONDITIONS OF PERMIT <br />D. Public A'otice Chances <br />Five commem letters were rereived l'y the Division during the 3G day public rommem period. Ses~eral clarifications <br />nrd changes were made to the draft permit based on these cornmems. <br />Several rommemers expressed concern with the need ro submit a copy of the SWMP to the CDMG. A major <br />concrrn was that other stater and EPA regions were oat requiring subminal of the plans. <br />In reviewing the issue, the Division roncluded that, jot facilities covered under the Sand and Gravel general <br />permit, plan dnrlopment and implenremariori it sti!! necessary, but submittal would only be required upon <br />specific x•rinen request by the Division or CDMG. One major benefit of this approach is that Division aid <br />CDMG resources con be better tuili;.ed in conducting field inspections and checking program implementation. <br />The injormaion colletred will then allow proper program adjustments at permit renewal (in five years). <br />Coordination x•irh CDMG wiU be through the due date of certification that the SWMP has been prepared and <br />implemented, which is based on the due date for the jarility's annual reclamation permit report to CDMG <br />during July l , 1993 ro June 30, 1994. /t is ;assumed that SWMP preparation may generate the need for <br />Technical revisions to the facility's reclamation permit through CDMG, aid sa the SWMP cert~cation due <br />dares are spread throughout the year ro stagger the CMG's x•orkload. <br />For any facilities covered uruler this permit Khich do nor also have a reclamation permit under CDMG, the <br />SWMP cert~cafion of completion and implementation v due by July 1, 1993. <br />2. One cornmenrer requested the rcmowil of rhti annual reporting requiremems jot srarmwarer discharges. Given <br />that submittal ojthe SWMP is na /anger automatic, tlu Division belinrs that the best overall method of <br />determining compliance by the regulated rorirmuniry, without imposing srorrrrwater monitoring requiremems, u <br />submittal of an annual report. The reporting requirements bast been scaled back to reflect the fact that the <br />Division will nor have a copy ojthe SWMP on hood 17n most cases). <br />In addition, the permit has been clarified ro show that no annual reports will be due 6ejore February IS, <br />1994. The permittee's rert~cation x•ill indi~crue the exact due date for the first annual report. <br />3. In response ro many comments from the construction and mining rommuniry, this permit coverage has been <br />broadened to include connete broth plants. Process water discharges from concrete batch pbnu (including <br />truck wash water) x•ill 6e subject to the numeric Iimits ar listed in Section V.A.I.a ojthe Rationale. <br />4. More derail has been added ro the comprehensisr inspeoion requiremems, for consistency with the Division's <br />other srarmwater general permits. <br />There were .cesrrnl other armmenr.r rrreisrd by the Division on this permit. The issuer raised have been addressed in <br />individual lerlers ro the commenters. This permit u subject to renewal in September, 1997. At that rime, appropriate <br />changes will 6e made in the permit to reflerY the'addirional knowledge and experience gained in the imerim. <br />Kathryn Dolan <br />August 24, 1992 <br />