2012-03-07_PERMIT FILE - C2010088 (21)

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COLORADO DEPARTMENT OF PUBLIC HEALTHAND ENVIRONMENT, Water Quality Control Division Rationale - Page 3. Permit No. COR- 010000 11. BACKGROUND The Environmental Protection Agency (EPA) requires that industrial stormwater discharges be regulated under the National Pollutant Discharge Elimination System (NPDES) program. (Note: The Colorado program is referred to as the Colorado Discharge Permit System, or COPS, instead of NPDES). The Water Quality Control Division ( "the Division') has stormwater regulations (SCCR 1002 -61) in place. These regulations require specific types of industrial facilities that discharge stormwater associated with industrial activity (industrial stormwater), to obtain a CDPS permit for such discharge. A facility which discharges industrial stormwater either directly to surface waters or indirectly, such as through municipal separate storm sewers, must be covered by a permit. A. General Permits The Division has determined that the use of general permits is the appropriate procedure for handling most of the thousands of industrial stormwater applications within the State. I. Types oJGeneral Permits: This permit covers abroad range of light industrial activities (see Section I11A -of the Rationale). Other stormwater general permits cover industrial activities for heavy industry, auto recycling, sand and gravel operations, construction activities and mining. 2. General vs. Individual Permit Coverage: Currently unpermitted facilities which the Division determines need to be covered under an individual permit (see criteria in Part LA.6 of the permit) may be temporarily covered under a general permit, if the Division determines that the benefits of immediate coverage outweigh the difference in permit requirements. The temporary coverage will be inactivated once an individual permit is issued (see Part LA.1c). Certification of a facility under a general permit does not in any way infringe on the Division's right to revoke that coverage and issue an individual permit or amend an existing individual permit, when such specialized facility attention is required. B. Cateroricallndustries Discharges of industrial stormwater must meet all applicable provisions of Sections 301 and 402 of the Clean Water Act. These provisions require control of pollutant discharges from categorical industries to a level equivalent to Best Available Technology Economically Achievable (BAT) and Best Conventional Pollutant Control Technology (BCT), and arty more stringent controls necessary to meet water quality standards. EPA regulations (40 CFR, Subchapter N) establish numeric effluent limitations for stormwater discharges from facilities in some of the industrial categories.' For these facilities, the numeric effluent limitations constitute BAT and BCT for the specified pollutants, and must be met to comply with this program. Currently, all facility types with numeric effluent limits for stormwater are covered under the general permit for Heavy industrial Activity, COR- 020000. See the permitfor Heavy Industry for a list of of ected industries. C. Permit Reouirements Thispermit does not require submission of effluent monitoring data in the permit application or in the permit itself. These light industries are considered to typically have a low potential fur pollutant levels in their stormwater discharges which would cause a water quality impact, due to the nature of activities occurring on site and the types of materials handled. The narrative requirements include prohibitions against discharges of nun - stormwater. They require dischargers to control and eliminate the sources of pollutants in stormwater through The development and implementation of a Slormwater Management Plan (SWAP). The plan must include BMPs, which may include treatment of stormwater discharges along with source reduction. Asper EPA, a fully implemented SWAP will constitute compliance with BAT and BCT. It is believed that BMPs are all that is necessary to control water quality impacts. If the Division determines that additional requirements are necessary, they maybe imposed as follows: ])at the renewal of this general permit or through an industry- special general permit if the issue is categorical; 2) through direction from the Division based on the implementation of a TMDL if the issue is watershed-based; or 3) if the issue is site-specific, through guidance from the Division, based on an inspection or SWMP review or through an individual permit.