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i <br /> COLORADO DEPARTMENT OF HEALTH, Water Quality Control Division <br /> Rationale - Page 4. Permit No. CO-0039136 <br /> III. DISCUSSION <br /> A. Total Suspended Solids - E.P.A. promulgated BAT regulations on <br /> November 26, 1982, but BCT (Best Conventional Pollutant Control <br /> Technology) is being reserved pending finalization of EPA's BCT cost <br /> methodology. Therefore, BPT shall apply. The SES limitation is not <br /> applicable pursuant to Section 10.1.3(3) of the State Regulations for <br /> Effluent Limitations, which states that when EPA has effluent <br /> limitations for an industry, the federal limitations shall take <br /> precedence. <br /> B. Alternate Limitations - As indicated in other sections of the <br /> rationale, some effluent limitations are or are not effective, <br /> dependent on occurrences of precipitation. Pages la and lb of the <br /> permit indicate when specific limitations apply. In order for the <br /> permittee to claim a "storm exemption" from the total suspended <br /> solids and total iron limitations, documentation of the eligible <br /> storm event must be submitted to the Division along with the <br /> appropriate discharge monitoring report (DMR) . <br /> C. Materials Containment Plan - Pages 6 and 7 of the permit describe the <br /> Materials Containment Plan (MCP) which is a requirement of all <br /> permittees. If a Spill Prevention Control and Countermeasure (SPCC) <br /> Plan has already been submitted by the permittee and approved by the <br /> Division, submittal of an annual update to this plan will satisfy the <br /> MCP requirement. <br /> D. Reopener Clause - This permit may be reopened and modified as <br /> discussed in Part II.B.5 if there is a significant change in state or <br /> federal water quality regulations, a significant change in operation <br /> at the facility, or at the request of the permittee. <br /> E. Reporting Frequency - The permittee has expressed concern about <br /> this. This permit recognizes quarterly reporting (Part I.B.1.) . <br /> This is the least frequent reporting period used in permits and l <br /> should not be a burden. <br /> Jon C. Kubic <br /> August 13, 1986 <br />