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. uw orrle%e • BRIAN N. GEDDES, P.C. 4197 HILTON PAfl KWAY. SUITE 112 COLORADO SPRINGS. COLORADO 80907 BRIAN N. OFD DE9 March 21, 1994 TELEPHONE I>le) aeo.nax IA% m of :eD.asee ~FC~~I/F~_, Mr. James Dillie MA~ Division of Minerals and Geology 'Ze?Jg94 Denverhe Oa80203eetalRoomo215eS ~~I~~sipROildij~N~c/s4L,ic,. `: T Re: Summit Pressed Brick and Tile Company Edmundson Clay Mine Permit No. M-85-203 Dear Mr. Dillie: I am writing to you as attorney for Summit Pres~ed Based on my review of the law, seminar material and my conversation with the Water Quality Control Division, I hope this letter will serve to explain the status on these permits and plans as applied to Summit. Brick and Tile Company concerning some confusion tha appears to exist concerning stormwater discharge permits and stormwater management plans. I am writing a virtuallly identical letter to each of the specialists for eachof Summit's permits. Summit has applied for each of it operations under a group permit application filed wi h the EPA by the Brick Institute of America and this has a parently caused some confusion. The EPA's stormwater regulations provide three different types of permits - individual, group, and general. Individual permits are apparently very rare, and you fare probably most familiar with general permits issued bye the State of Colorado Water Quality Control Division, particularly Permit No. COG-500000, based on an EPA del. Group permits, however, are submitted to the EPA, wh must approve it and issue a model group permit. NPDES sta es with group permit authority, like Colorado, then can issu a group permit based on that model. In the case of Summit, a Brick Institute of America has applied to the EPA for a gr p permit covering clay mines and brick manufacturing si es. The draft permit is required to be published in the deral Register and it was published in 58 Fed. Reg. No. 222,. The EPA waits a 90 day period for public comment after publication and then will finalize the permit. The p~rmit has not been finalized at this point. Once the perms is III IIII~IIIIIIII III