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<br /> <br />COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division <br />Rationale - Page 4. Permit No. CO-0037605 <br />DISCUSSION: <br />A. Total Suspended Solids - E.P.A. promulgated BAT regulations on November 26, <br />1982, but BCT (Best Conventional Pollutant Control Technology) is being <br />reserved pending finalization of EPA's BCT cost methodology. Therefore, <br />BPT shall apply. The SES limitation is not applicable pursuant to Section <br />10.1.3(3) of the state Regulations for Effluent Limitations, which states <br />that when EPA has effluent limitations for an industry, the federal <br />limitations shall take precedence. <br />B. Alternate Limitations - As indicated in other sections of the rationale, <br />some effluent limitations are or are not effective, dependent on <br />occurrences of precipitation. Pages la and 16 of the permit indicate when <br />specific limitations apply. In order for [he permittee to claim a "storm <br />exemption" from the total suspended solids and total iron limitations, <br />documentation of the eligible storm event must be submitted to the division <br />along with the appropriate discharge monitoring report (Dh4t). <br />C. Materials Containment Plan - Pages 6 and 7 of the permit describes tfie <br />haterials Containment Plan (h1CP) which is a requirement of all permittees. <br />If a Spill Prevention Control and Countermeasure (SPCC) Plan has already <br />been submitted by the permittee and approved by the division, submittal of <br />an annual update to this plan will satisfy the MCP requirement. <br />D. Reopener Clause - This permit may be reopened and modified as discussed in <br />Part II.B.S if there is a significant change in state or federal water <br />quality regulations, a significant change in operation at the facility, or <br />at the request of the permittee. <br />Jon Kublc <br />March 12, 1986 <br /> <br />