2009-11-12_HYDROLOGY - M1984043 (2)

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PART II Permit - Page 29 of 23 Permit No. COR-340000 `VII. CHANGES AFTER PUBLIC NOTICE Written comments were received from the Colorado Rock Products Association during the public notice period. Response to these comments is discussed below. A. Comment: The permit requires that existing permittees update their SWMPs, if necessary, to incorporate additional requirements for the site map, description ofpotentialpollutant sources, and stormwater management controls. The deadline for this update is February 1, 2008. It was requested that permittees be allowed additional time to complete the update, as some entities have numerous sites. (See Part I.B(2) of the permit.) Response: The SWMP changes are not extensive, and are not expected to require substantial time to complete. However, the deadline was extended to March 1, 2008. B. Comment: The permit requires that, , for most sites, inspections of'the facility's stormwater management system is required twice a year, in the spring and fall. It was requested that the permit not specifv an exact timefiwme for these inspections. (See Part I..B(S) of the permit.) Response: The spring and_fall timeframes were included so as to avoid having the two required inspections conducted too close together. The permit has been changed to state that the twice yearly inspections are required "approximately" in spring and.fall. If this is not possible, the inspections must be conducted at least 120 days apart. Note that at least two inspections must still be conducted within each calendar year, and reported on the following Annual Report. C. Comment:. The permit requires that a copy of the SWMP be retained on site for active mines, and mines undergoing reclamation. It was requested that, , for sites undergoing reclamation, the SWMP be retained by the permittee, but not necessarily on site. (See Part LB(7)(b) of the permit.) Response: The reason for maintaining the SMWP on site is to ensure that the plan is readily accessible to those who are working on the site (such as BMP installation and maintenance staff), as well as to state and local inspectors. This is the default requirement, and is expected to be feasible at the vast majority of sites. The permit has been changed to allow for the SWMP to be retained at another location, provided that it is approved by the Division. The allowance for an alternate location is intended for specific circumstances, to take into account operations that do not have a suitable on-site location where the SMWP may be maintained. D. Comment: The permit states that the Division has the authority to require continued permit coverage, even if the site has been reclaimed, if the Division has shown or has reason to suspect that the stormwater discharges may contribute to a violation of a water quality standard. It was requested that the Division include a rationale for this provision. (See Part LD(2) of the permit.) Response: This provision, part of Regulation 61, Colorado Discharge Permit Regulations, section 61.3(2)(e)(vii), is standard in all stormwater discharge permits. It gives the Division the discretion to require permit coverage whenever water quality standards may be jeopardized, regardless of the source. No changes were made to the permit. E. Comment: The permit authorizes access to the site by the Division, EPA, and/or their authorized representative(s). Concerns were raised regarding safety, liability, and insurance issues, if inspectors access the site without notiing mining personnel, or access the site without the required training or escort. (See Part ILB(1) of the permit.) Response: Although the Division understands the concerns included in the comment, the comment addresses Division and EPA procedures and is therefore outside of the scope of the permit. No changes were made to the permit. Kathryn Dolan August 27, 2007