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COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT, Water Quality Control Division <br />Rationale — Page 13, Permit No. C00036251 <br />B. Monitoring <br />Effluent Monitoring — Effluent monitoring will be required as shown in the permit document. Refer to <br />the permit for locations of monitoring points. Monitoring requirements have been established in <br />accordance with the frequencies and sample types set forth in the Baseline Monitoring Frequency, <br />Sample Type, and Reduced Monitoring Frequency Policy for Industrial and Domestic Wastewater <br />Treatment Facilities. This policy includes the methods for reduced monitoring frequencies based upon <br />facility compliance as well as for considerations given in exchange for instream monitoring programs <br />initiated by the permittee. This facility does not meet the requirement for performance -based <br />reductions in monitoring due to compliance issues with the previous permit. <br />Ensure Numeric Effluent Limits Can Be Met <br />Prior to the commencement of any discharge, the treated effluent must be sampled using grab method <br />for all parameters with a numeric limitation. All effluent must be contained until analyses have <br />confirmed that all numeric effluent limitations have been met. If the results of the initial sampling <br />exceed any numeric effluent limitation, additional treatment shall be completed and additional <br />sampling must be collected, post- treatment, to confirm compliance with the limitations. Additional <br />sampling and treatment shall be repeated, and all water shall be collected and retained, until monitoring <br />results for the treated effluent verify compliance with the numeric effluent limitations identified in the <br />permit. This requirement will not be imposed for TDS where report only is required. <br />C. Reporting <br />1. Discharge Monitoring Report — The Cotter Corporation facility must submit Discharge Monitoring <br />Reports (DMRs) on a monthly basis to the Division. These reports should contain the required <br />summarization of the test results for all parameters and monitoring frequencies shown in Part I.A of the <br />permit. See the permit, Part I.A, B, C and D for details on such submission. <br />2. Special Reports — Special reports are required in the event of an upset, bypass, or other noncompliance. <br />Please refer to Part II.A. of the permit for reporting requirements. As above, submittal of these reports <br />to the US Environmental Protection Agency Region VIII is no longer required. <br />D. Additional Terms and Conditions <br />1. Signatory and Certification Requirements — Signatory and certification requirements for reports and <br />submittals are discussed in Part I.D.6. of the permit. <br />E. Waste Minimization/Pollution Prevention <br />Waste minimization and pollution prevention are two terms that are becoming increasingly more <br />common in industry today. Waste minimization includes reducing the amount of waste at the source <br />through changes in industrial processes, and reuse and recycling of wastes for the original or some other <br />purpose (such as materials recovery or energy production). Pollution prevention goes hand -in -hand with <br />waste minimization. If the waste is eliminated at the front of the line, it will not have to be treated at the <br />end of the line. The direct benefits to the industry are often significant, both in terms of increased profit <br />and in public relations. This program can affect all areas of process and waste control with which an <br />industry deals. Elimination or reduction of a wastewater pollutant can also result in a reduction in an air <br />pollutant or a reduction in the amount of hazardous materials that must be handled or disposed. <br />