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• uw orneLe • <br />BRIAN N. GEDDES. P.C. <br />49D9 HILTON PARKWAY, bU ITE 112 <br />COLORADO SPRINGS. COLORADO 80907 <br />BRIAN N. OLDDLY <br />April 4, 1994 <br />RF.~FIVI=r. <br />Mr. Robert c. Oswald APR ~ S 1994 <br />Environmental Protection Specialist ~,,,..;^ <br />Division of Minerals & Geology ~^'P^,~t~~;.n~~~,~n~ <br />1313 Sherman Street <br />Room 215 <br />Denver, Colorado 80203 <br />Re: Summit Pressed Brick and Tile Company <br />Calhan Pit/File No. M-93-080 <br />Dear Bob: <br />TELEPHONE <br />ITIB) LBO•TTL1 <br />IA; <br />ITU) aao•o!e <br />I would like to include this letter in Summit's file on <br />the above permit to clarify some matters on the stormwater <br />management plan submitted with this application. Because <br />this was a new permit application, which we understood <br />required a stormwater management plan, and because Summit <br />wanted to reassure any potential objectors that the operation <br />would be conducted in a safe manner, Summit prepared a <br />stormwater management plan for this pit based on the Colorado <br />Contractors' Association model stormwater management plan. <br />This may have tomamended later, as explained below. <br />EPA's stormwater regulations allow, in addition to the <br />more common general permits, group permits. Apparently the ~ <br />general permits issued by the State of Colorado Water Quality `~,~~ <br />Control Division are the most common. However, Summit has ~~,,+k <br />applied for each of its operations under a group permit /i,~'e <br />application filed with the EPA by the Brick Institute of_,. <br />America. The EPA must approve this group permit and issue a <br />model group permit based on it. NPDES states with group <br />permit authority, like Colorado, then issue a group permit <br />based on that model. The draft permit is required to be <br />published in the Federal Register and was published in 58 <br />Fed. Reg. No. 222. There is a waiting period for public <br />comment after which the EPA finalizes the permit. Once it is <br />finalized, the members within the group have 270 days to <br />prepare pollution prevention plans (PPP), which are the EPA's <br />designation of a stormwater management plan. <br />iii iiiiiiiiiiiii iii <br />999 <br />According to Kathy Dolan at water Quality Control <br />Division, once the group permit is issued, WQCD will, in <br />