GENERAL42848

• Permit No: M1977317
• IBM Index Class Name: General Documents
• Doc Date: 3/23/1994
• Doc Name: SUMMIT PRESSED BRICK AND TILE CO CEDARWOOD CLAY MINE PN M-77-317
• From: BRIAN N GEDDES PC
• To: DMG
• Media Type: D
• Archive: No

BRIAH N. OEOOES
• uw O/rlCes •
BRIAN N. GEDDES. P.C.
4785 HILTON PAPKWAY. SUITE 112
COLORADO SPRINGS. COLORADO 80907
March 21, 1994
TELEPHONE
(710) 160-TT12
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Mr. James Dillie MqR
Division of Minerals and Geology 2 3 19gq
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D1313rShermanfStreetalRoom 215e5 ~~ns Mn,t.,.
Denver, CO 80203 u"' ° ~'~uI~BY
Re: Summit Pressed Brick and Tile Company
Cedarwood Clay Mine Permit No. M-77-317
Dear Mr. Dillie:
I am writing to you as attorney for Summit Pressed
Brick and Tile Company concerning some confusion that appears
to exist concerning stormwater discharge permits and
stormwater management plans. I am writing a virtually
identical letter to each of the specialists for each of
Summit's permits. Summit has applied for each of its
operations under a group permit application filed with the
EPA by the Brick Institute of America and this has apparently
caused some confusion. Summit has included the Cedarwood pit
in this group application as agent for the operator, Red
Mountain Clay Company.
Based on my review of the law, seminar materials, and
my conversation with the Water Quality Control Division, I
hope this letter will serve to explain the status on these
permits and plans as applied to Summit.
The EPA's stormwater regulations provide three
different types of permits - individual, group, and general.
particularly Permit No. COG-500000, based on an EPA model.
Group permits, however, are submitted to the EPA, who must
approve it and issue a model group permit. NPDES states with
group permit authority, like Colorado, then can issue a group
permit based on that model. In the case of Summit, the Brick
Institute of America has applied to the EPA for a group
permit covering clay mines and brick manufacturing sites.
The draft permit is required to be published in the Federal
Register and it was published in 58 Fed. Reg. No. 222. The
EPA waits a 90 day period for public comment after
Individual permits are apparently very rare, and you are
probably most familiar with general permits issued by the
State of Colorado Water Quality Control Division,
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