HomeMy WebLinkAbout1.02 Water quality divisionATIACHMENT to SPECIAL USE PERMIT APPLICATION laramie Energy II, LLC CO Department of Public Health and Environment Water Quality Control Division (Permit No. COG·600000. Facility No.
COG60100S1
STATE OF COLORADO Bill Riner, Jr., Governor James B. Martin, Executive Director Dedicated to protecting and improving the health and environment of the people of Colorado 4300 Cherry
Creek Or. S. laboratory Services Division Denver, Colorado 80246-1530 8100 Lowry Blvd. Phone (303) 692-2000 Denver, Colorado 80230-6928 TOO Line (303) 691-7700 (303) 692-3090 Located
in Glendale, Colorado http;lIwww.cdphe.state.co.u5 April 14, 2008 Malthew Bruff, Chief Development Officer, Altela, Inc Altela, Inc. 5350 S. Roslyn Street Englewood, CO 80 I I I Bob
Hea. Vice President Laramie Energy II. LLC 1512 Larimer Street. Suite 1000 Denver. CO 80202 RE: Certification, Colorado Wastewater Discbarge Permit System Permit No., COG-600000, Facility
Number: COG601008 Dear Mr. Hea and Mr. Bruff; Colorado Depanment of Public Health and Environment Enclosed please find a copy of your certification, which was issued under the Colorado
Water Quality Control Act. You are legaUy obligated to comply with aU terms and conditions of the permit and certifications_ Please read the permit and the certification; if you have
any questions contact me at (303) 692-3531, Sincerely, /, (~/'1~ I ! Debbie Jessop, Administrative Assistant Water Quality Protection Section WATER QUALITY CONTROL DIVISION Enclosure
xc; Regional Council of Government Garfield County, Local County Health Department Mark Kadnuck, D,E., Technical Services Unit, WQCD Permit File Permit Fees /lh cert
Pe,miI No. COG..()6(){)()()() Facility No. COG-60IOOB Page I Colorado Discharge Permit System Regulations (Regulation No. 61) CERTIFICA TION under GENERAL PERMIT FOR MINIMIAL INDUSTRIAL
DISCHARGE (SIC No: /629) Category 26, Subcategory 2, General Pennits, Current fee $630/10ng tenn (CRS 25-8-502) This certification specifically authorizes: Altela, Inc. and Laramie Energy
to discharge as described below and in accordance with the general pennit for Minimal Industrial Discharges. All correspondence relative to this facility should reference the specific
facility number, COG-601008. Permittees Contacts Altela, Inc. 5350 S. Roslyn Street Englewood, CO 80 III Matthew Bruff, Chief Development Officer, Altela, Inc. Phone: 303-993-1950 Laramie
Energy II, LLC 1512 Larimer Street, Suite 1000 Denver, CO 80202 Project Name, Activity and Location Bob Hea, Vice President Phone: 303-339-4000 Altela Piceance Natural Gas Water Treatment-The
activity consists of treating groundwater from natural gas extraction activities. The treatment process involves heating the groundwater to fonn steam, and discharging the condensate.
The evaporation treatment is designed to remove contaminants and essentially produce distilled water. Since contaminants that do not evaporate are left behind in the concentrate water,
this permit only covers discharges from the treated condensate. The project is located at 210 I County Road 321 in Rifle (Garfield County), Colorado Discharge Points The discharge points
(00 I A and 002A) are located at (00 I A) Latitude: 39" 30'54"N Longitude: -107° 48' 40" W and (003A) Latitude: 39° 30'22"N Longitude: -107° 48' 21" W. Periods of discharge will be higher
during winter months, when re-use demand is low. c-Discharge Point I Estimated Flow Rate ---''---------r-Description ! OOIA 002A Effluent Limitations The thennal distillation condensate
will flow to an unnamed draw to the Colorado River The thennal distillation condensate will flow to an Helmer Gulch draw prior to reaching the Colorado River Max. ~7GPM Max. ~7GPM ~
_____ ..J The discharges are to Segment 04a of the Lower Colorado River Sub-basin, Lower Colorado River Basin, found in the Classifications and Numeric Standards for the Lower Colorado
River Basin (Regulation No. 37 last update effective March I, 2008). Segment 04a has been designated Reviewable, and is classified for the following beneficial uses: Aquatic Life, Class
2 (Cold); Recreation Class 2; Water Supply; and Agriculture. ISSUED AND EFFECTIVE: APRIL14 ! 2008 EXPIRATION JULY 31.2006 ADMINISTRA TlVEL Y EXTENDED
Permit Limitations and Monitorin~ Reauirements Dlscharge_ Limitations Parameter Maximum Concentrations 30-Uay 7-Day Average Average DaiJyMax. 2-Yr Avg Pe,mil No. COG..()6(){)(JOO Facility
No. COG-60JOO8 Page 2 Monitoring SampJeType Frequency Instantaneous Flow. MGD Report NA Report NA Monthly or Continuous Total Suspended Solids. mg/I 30 45 NA NA Monthly Grab Oil and
Grease, mg/I NA NA 10' NA Monthly Visual* pH, S.u. (Minimum-Maximum) NA NA 6.5-9.0 NA Monthly In-situ Site-Specific -.v.no1e. Emuent Toxicity, Chromc Stat Diff and IC25 ?: IWC NA Quarterly
3 Grabrrest Naphthalene, ug/I 140 NA 2,300 21 Monthly Grab Total Dissolved Solids mg/I Report NA Report NA Monthly Grab Instantaneous Temperature, 0 C 20° NA NA NA Monthly or Continuous
* There shall be no Visible sheen. If a Visual sheen IS detected, a grab sample must be collected Other Conditions Because the Material Safety Data Sheets (MSDS) sheets for chemicals
that Laramie Energy utilizes in production activities do not contain comprehensive studies or specific named chemicals, the WQCD is requiring an annual analysis for the volatiles, base/neutrals,
acids. and metals found in Appendix A of the Minimal Industrial General Permit Application, and an analysis for the Hazardous Substances found in Appendix B of the application. This
screen shall be conducted after use of the chemicals disclosed in the application, and submitted to the WQCD within 7 days of receiving laboratory results. The first analysis must be
conducted prior to October I, 200S, assuming gas production activities are underway. Antidegradation -As set out in The Basic Standards and Methodologies of Surface Water, Section 31.S(3)(c)(ii)(C),
an antidegradation analysis is required for all waters not designated as Use Protected, except in cases where the regulated activity will result in only temporary or shott term changes
in water quality, or where the ratio of the low flow to the facility flow is 100: I or more. These discharges are not temporary or short-term, and to not fall under the flow exemption,
thus, these discharges are not exempted from an antidegradation review. Under this cettification, an antidegradation (AD) limit will be calculated as 15% of the chronic Water Quality
Standard for naphthalene. An individual permit will be required where the permittee requests consideration of dilution and ambient water quality. Antidegradation limits apply as the
average of all data collected for months in that group during a rolling 24-month period. These limits become effective after data has been collected for all months in the group during
the 24 months following permit issuance, and the limit will become effective in the 24th month in which the permit is effective. Rationale for Site-Specific Parameters Temperature Since
the treatment process involves adding a significant amount of heat to the water. Heat is a pollutant of concern for this discharge.
Chemicals Permit No. COG..()6()()()OO Facility No. COG-6lilOO8 Page 3 Laramie Energy will be using LOSURF-300 SURFACTANT in the production process. According to the MSDS sheet, this
formula contains naphthalene. Thus, naphthalene has been added to the permit limitations. Altela and Laramie Energy have also disclosed several additional chemicals (fracturing agents,
etc) which will be used during periods of gas production, and may be introduced to the groundwater. Many of these chemicals do not have toxicology data available. Thus, Whole Effluent
Toxicity (WET) testing has been added to this certification. Whole Effluent Toxicity (WET) Testing Purpose of WET Testing -The Water Quality Control Division has established the use
of WET testing as a method for identifYing and controlling toxic discharges from wastewater treatment facilities. WET testing is being utilized as a means to ensure that there are no
discharges of pollutants "in amounts. concentrations or combinations which are harmful to the beneficial uses or toxic to humans, animals, plants, or aquatic life" as required by Section
31.11 (I) of the Basic Standards and Methodologies for Surface Waters. a. Testing and Reporting Requirements Tests shall be done at the freguency listed above. Test resuhs shall be reported
along with the Discharge Monitoring Report (DMR) submitted for the reporting period during which the sample was taken. (Le., WET testing results for the first calendar quarter ending
March 31 shall be reported with the DMR due April 28.) The results shall be submitted on the Chronic Toxicity Test report form. available from the Division. Copies of these reports are
to be submitted to both the Division and EPA along with the DMR. The permittee shall conduct each chronic WET test in general accordance with methods described in Short Term Methods
for Estimating the Chronic Toxicity of Effluents and Receiving Waters to Freshwater Organisms. EPA1600/4-89/00 I or the most current edition. except as modified by the most current Division
guidance document entitled Guidelines for Conducting Whole Effluent Toxicity Tests. The permittee shall conduct such tests using Ceriodaphnia dubia and fathead minnows. b. Failure of
Test and Division Notification A chronic WET test is failed whenever I) there is a statistically significant difference in lethality between the control and any effluent concentration
less than or equal to the instream waste concentration ("IWC") J!!!l!, 2) the IC", which represents an estimate ofthe effluent concentration at which 25% of the test organisms demonstrate
inhibition as reflected by lethality, is at any effiuent concentration less than or equal to the IWe. The IWC for this permit has been determined to be 100%. The permittee must provide
written notification of the failure of a WET test to the Division. along with a statement as to whether a Preliminary Toxicity Investigation ("PTI")!foxicity Identification Evaluation
("TIE") or accelerated testing is being performed (see Part d.). Notification must be received by the Division within 21 calendar days of the demonstration of chronic WET in the routine
required test. "Demonstration" for the purposes of Parts .b .. c., d. and f. means no later than the last day ofthe laboratory test. c. Automatic Compliance Schedule Upon Failure of
Test If a routine chronic WET test is failed, the following automatic compliance schedule shall apply. As part of this, the permittee shall either: L Proceed to conduct the PTl!fIE investigation
as described in Part d, or iL Conduct accelerated testing using the single species found to be more sensitive. If accelerated testing is being performed, Ihe permittee shall provide
written notification of the results within 14 calendar days of completion of the "Pattern of Toxicity"I"No Toxicity" demonstration. Testing will be at least once every two weeks for
up to five tests until; I) two
Permit No. COG-f)6(}()OOO Facility No. COG-6lJ1OO8 Page 4 consecutive tests fail or three of five tests fail, in which case a pattern of toxicity has been demonstrated or 2) two consecutive
tests pass or three of five tests pass, in which case no pattern of toxicity has been found. If no pattern of toxicity is found the toxicity episode is considered to be ended and routine
testing is to resume. If a pattern of toxicity is found, a PTi/TiE investigation is to be performed. If a pattern of toxicity is not demonstrated but a significant level of erratic toxicity
is found, the Division may require an increased frequency of routine monitoring or some other modified approach. d. PTlrrIE The results of the PTlrrlE investigation are to be received
by the Division within 120 days of the demonstration of chronic WET in the routine test. as defined above. or if accelerated testing is oerformed. the date the pattern of toxicilY is
demonstrated. A status reoort is to be provided to the Division at the 30. 60 and 90 day points of the PTlrrlE investigation. The Division may extend the time frame for investigation
where reasonable justification exists. A request for an extension must be made in writing and received prior to the 120 day deadline. Such request must include a justification and supporting
data for such an extension. The permittee may use the time for investigation to conduct a PTI or move directly into the TIE. A PTI consists ofa brief search for possible sources of WET,
which might reveal causes of such toxicity and appropriate corrective actions more simply and cost effectively than a formal TIE. If the PTI allows resolution of the WET incident, the
TIE need not necessarily be conducted. If, however, WET is not identified or resolved during the PTI, the TIE must be conducted within the allowed 120 day time frame. Any permittee that
is required to conduct a PTlrrlE investigation shall do so in conformance with procedures identified in the following documents, or as subsequently updated: I) Toxicity Identification
Evaluation: Characterization of Chronically Toxic Effluents. Phase I, EPN600/6·9J1005F May 92, 2) Methods for Aquatic Toxicity Identification Evaluations, Phase I Toxicity Characterization
Procedures, EPN600/6-91/003 Feb. 91 and 3) Methods for Aquatic Toxicity Identification Evaluations. Phase II Toxicity Identification Procedures, EPA/600/3-88/035 Feb. 1989. A fourth
document in this series is Methods for Aquatic Toxicity Identification Evaluations. Phase III Toxicity Confirmation Procedures, EPA/600/3-881036 Feb. 1989. As indicated by the title,
this procedure is intended to confinn that the suspected toxicant is truly the toxicant. This investigation is optional. Within 90 days of the determination of the toxicant or no later
than 210 days after demonstration of toxicity, whichever is sooner, a control program is to be developed and received by the Division. The program shall set down a method and procedure
for elimination of the toxicity to acceptable levels. e. Request For Relief The permittee may request relief from further investigation and testing where the toxicant has not been determined
and suitable treatment does not appear possible. In requesting such relief, the permittee shall submit material sufficient to establish the following: i. It has complied with terms and
conditions of the permit compliance schedule for the PTVTlE investigation and other appropriate conditions as may have been required by the WQCD; ii. During the period of the toxicity
incident it has been in compliance with all other permit conditions, including, in the case of a POTW, pretreatment requirements; iii. During the period of the toxicity incident it has
properly maintained and operated all facilities and systems of treatment and control; and iv. Despite the circumstances described in paragraphs (i) and (iii) above, the source andior
cause of toxicity could not be located or resolved.
Permit No. COG.{)6(J()()(J(J FaciliJy No. COG-6lJlOO8 PageS If deemed appropriate by the Division, the permit or the compliance schedule may be modified to revise the ongoing monitoring
and toxicity investigation requirements to avoid an unproductive expenditure of the permittee's resources, provided that the underlying obligation to eliminate any continuing exceedance
of the toxicity limit shall remain. f. Spontaneous Disappearance If toxicity spontaneously disappears at any time after a test failure, the permittee shall notity the Division in writing
within 14 days ofa demonstration of disappearance ofthe toxicity. The Division may require the permittee to develop and submit additional information, which may include, but is not limited
to, the results of additional testing. Ifno pattern of toxicity is identified or recurring toxicity is not identified, the toxicity incident response is considered closed and normal
WET testing shall resume. g. Toxicity Reopener This permit may be reopened and modified (following proper administrative procedures) to include new compliance dates, additional or modified
numerical permit limitations, a new or different compliance schedule, a change in the whole effluent toxicity testing protocol, or any other conditions related to the control of toxicants
if one or more of the following events occur: i. Toxicity has been demonstrated in the effluent and the permit does not contain a toxicity limitation. ii. The PTlrrlE results indicate
that the identified toxicant(s) represent pollutant(s) that may be controlled with specific numerical limits and the permit issuing authority agrees that the control of such toxicants
through numerical limits is the most appropriate course of action. iii. The PTlrrlE reveals other unique conditions or characteristics, which, in the opinion of the pennit issuing authority,
justify the incorporation of unanticipated special conditions in the permit. WET test results shall be reponed along with the Discharge Monitoring Repon (DMR) submitted for the reponing
period during which the sample was taken. (i.e., WET testing results for the first calendar quaner ending March 31 shall be reponed with the DMR due April 28.) The results shall be submitted
on the Chronic Toxicity Test repon fonn, available from the Division. A copy of this report is to be submitted to both the Division along with the DMR. Best Management Practices The
permittee shall implement and maintain the Best Management Practices (BMP) for the prevention of erosion and the control of solid and liquid pollutants due to the discharge. BMPs include
various options, such as: modification of the pipe discharge structure to disperse flows; containment of water by hay bales or other comparable structures; the use of geocloth, filter
fabric, or plastic sheeting for protection of containment structures; rip-rap; anellor any other approved methods. The General Minimal Industrial Discharge Permit is attached. If the
permittee has questions related to this certification, contact the penn it writer. Permit Writer Erin Scott 303.692.3506 April 9, 2008
RATIONALE MINIMAL DISCHARGE GENERAL PERMIT IN COLORADO COLORADO DISCHARGE PERMIT NUMBER COG-600000 The significant changes in this first renewal permit are as follows: A. Impacted Stream
Segments: For this general permit, any existing or new operation that discharge to a segment that is listed on the Division's 303(d) list of impacted stream segments will be dealt with
on a case-by-case basis. The 303(d) segments are segments that are impacted by metals and other pollutants. For most, ifnot all, of the operations that discharge under this permit, there
are no monitoring data to verifY the expectation that these discharges will not impair the listed segments. Therefore, for those facilities that discharge to segments on the 303(d) list,
the permittees will be required to perform a one-lime analysis for the listed parameters of concern 10 confirm that these stream standards are not exceeded in the discharge concentrations.
Because the receiving waters are included on the state's 303(d) list, total maximum daily loads (TMDLs) are being developed in accordance with the Division's schedule for TMDL completion.
Once a TMDL has been established. if it is necessary to incorporate limitations for a facility certified under this general permit which are based upon the outcomes of the TMDL or the
results of the onelime analysis, an individual permit may be written 10 regulate discharges from this facility. The facility would continue to be covered under Ihis general permit certification
until/he individual permit was issued. B. Regulation Numbering System: The Colorado Water Quality Control Commission has recently changed the regulation numeration to "achieve a more
logical organization and numbering of the regulations, and to make the initial numbering system and that of the Code of Regulations consiSlent." The changes are reflected in the permit.
C. Discharge Monitoring Reports (DMR): It is no longer necessary to send duplicate copies of Discharge Monitoring Reports (DMR) to the Environmental Protection Agency, Region 8. Hence,
US EPA, Region 8 has been removedfrom Partl.D. I. of the general permit. D. Whole EjJluent Technology (WET) testing reqUirements were changed to aI/ow for flexibility of determining
monitoring frequency of test based upon the toxicological history of the discharge, see Part I.B.2.1. <;. The Division saw the need to provide variance in effluent parameters and monitoring
frequencies on a site-specific basis. Currefllly, these parameters and monitoring frequencies apply routinely for cenificalions issued under this permit. However, there are cenain situations
where the Division has determined that there is a justifiable basis to modify the permit requirements for one or more parameters for cenain outfal/s, but the permit does not provide
for such situations. This permit will aI/ow for modijicalions with proper documemalion. The categories to which this permit covered were removed from the permit so thal coverage would
be determined on a case-by-case basis. The ability to characterize the type of discharge and the magnitude of contamination is necessary to determine the parameter(s) requiring monitoring.
The parameters identified. their numeric concentrations. an.d monitoring frequencies will be determined on a site-specific basis and will be indicaled in the cenificalion. The following
are cOlegories thal include parameters and monitoring frequencies thal !!!!!l! be included in the cenification specifically tailored to the lIOlure of the discharge. a. Facilities discharging
wastewater from washing the exteriors of trucks, cars, airplanes, boats (in dry dock), driveways, parking lots, and roads shall comply with the following limitations unless the Division
impases additional monitoring. See the facility certification for a complete list o[parameters and limitations. I Dischaf e Limitations ! Effluent Parameter 30 Day I 7 Day , Daily I
Frequency Sample Type i Ave. . Ave : Max i Flow, m Re art I NA ' Re ort ,Weeki Instantaneous ~_ Total Suspended Solids, mglL ---+-----#' 45 NA Monthly Grab _: ~_ Total BTE)(, mglL _
iNA_+--NA o. I, Monthl Grab , _ _JEi,s.u. I NA ' NA 6.5-9.0 Weeki In-situ ==JJiI and G!.ease, mglL NA NA 10 Weekly Visual.
COLORADO DEPARTMENF OF PUBLIC HEALTH AND ENVIRONMENT, Water Qunlity Contral Division Rmionaie ~ Page 2, Permit No. COG·6lXXJOO b, c, d e, Facilities discharging wastewater from the washing
of bleachers, elevated seating, and grandstands, such as thasefound at aU/door sporling or entertainment evenls shall comply with the following limitations unless the Division imposes
additional monitoring. See the facilif)' certification for a complete list 0/parameters and limitations. . -f.-Discharge Limitations ; i Effluent Parameter ! 30 Day: 7 Day : Daily ~
Frequency Sample Type : Ave. i Ave I Max 'I , ------oF"'lo-w-,-g-p-m-----+-1 '"'R"e"'port! NA I Report: Instantaneous 1 Total Suspended Solids, mf!!L ! 30 ! 45 ' NA ! Grab 'fjj;,logicalOxygen
Demand, mf!!L' 30 45 i Report! f-'I' _____ "'G"'r"'a"'b'_____ ___ --' __ pH, s,u, ,NA NA 16,5-9,0 i Twice per Dischargef-____ --"Sn"'-s"'i"'tu"-____ --l : Fecal coliform Bacteria, #1100
ml ! NA NA I •• 1 f-' ____ "'G~r"'ao;b'--------_--1 ,-E. Coli, #1100 ml ! NA NA Report i I Grab , 'N" N."! 10 1 f-------o""-'~----__1 Oil and Grease, mf!!L '" I '" '-----'-"'----~ _______
__"__ ____ --'V_'i"'su"'a"'l"_, ___ ----' Facilities discharging wastewater from the draining, cleaning, andftlter backwash of swimming pools, spas, hot tubs, and similar structures
including waler slides, and waler theme amusements shall comply with the following limitations unless additional monitoring is imposed by the Division. See the facility certification
for a compiete list of parameters and limitations. E.fJluent Parameter 'I' Discharge Limitations i 30 Day I 7 Day I Daily : Frequency Sample Type I Ave. i Ave : Max I Flow, gpm ' NA
'Re art Instanlaneous Total Sus ended Solids, m IL 45 NA Grab Total Residual Chlorine, mglL '," NA •• I' Grab ~~;o---.--cB;s:r-"o"'m"'i:;;n"'e,c.m=g!'-'L'-n_";o;;;_~Ir-'7,··,--+---'N.~A7-~,r-••,
,.;--Ii Twice per Discharge ~,= =========~G~r~a~b==========~ ,Fecal colifOrm Bacteria, #1100 ml NA NA!" I i' ____ ---7G"r-=a';'b ____ -----I ~-pH, s,U, NA NA 16,5-9,0 j I--____ --'l"'n"'-s"""'-tu:;--
-___ --, Oil and Grease, mgIJO-_..L..----'-N."'AO-_ ~,----'-IO'------', ___________ ____'_V_=is"u"'a"_I ___ _.J Facilities discharging wastewater from the washing of temporary stables,
traveling petting zoas, emergency discharge from unpermilled domestic wastewater treatment facilities that may involve the dewatering of lagoons or any other facility that discharges
wash water associated with human/animal wastes, shall comply with the following limitations unless the Division imposes additional monitoring. See the facility certification for a complete
list of parameters and {~'!!i~_at_io_ns_, .. -------~--cC'C'__c_-____,c-c---c--___c-~--------,---------------, Discharge Limitations Effluent Parameter ! 30 Day , 7 Day : Daily Frequency
Sample Type I Ave, ! Ave ' Max I ; Re20rt I NA I Report I Instantaneous L 30 45, NA I , Grab 30 45 NA : Twice per Discharge 1 Grab NA NA •• Grab Re{!Orl NA Repprl i ! NA NA 6~ II In-situ
NA NA 10 I Visual Facililies discharging wastewater groundwater from foundation, basement. underground structure dewatering, or during well water pump tests shall comply with the following
limitations unless additional monitoring is imposed by the Division. See the acili cera Ication or a com tete lislo arameters and limitations. Discharge Limitations E.ffIuent Parameter
130 Day I 7 Day Daily I , Ave. I Ave max I Frequency Sample Type Flow, gam , Report i NA Report I 1f-__ ---"ln"'s-,t"a"'nr"a"n"e"o"u,.,s'_____ _ --1 Total Sus ended Solids, m IL '30
45 44-ni T ' D' h " ____ --,G=ra"'b"----____ -1 , pH, s, u, ,NA 6.5J2i wtce per tSC arge 1-In-situ r------Oil and Grease, mg/L .l_~ 10 ~1--------':V:;;isc"u:.::a"'I;----------1
COLORADO DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT Waw Quality Control Division Rationale -Page 3. Permit No. COG-6OOfXJO f F acilil ies discharging non-contact cooling or heating
water shall comply with the following limitations unless the Division imposes additional monitoring. See the [acility certification fOr a complete list ofparameters and limitations.
-.-.~ . .-1 Discharge Limitations i Effluent Parameter i 30 Day I 7 Day Daily Frequency Sample Type A ve. 'I A ve max I , Flow, Kpm Report I NA I Report i Weekly Instantaneous : T;tal
Suspended Solids, mglL 30 45 NA I Monthly Grab Teme.erature, °C NA NA • Weekly In-situ , ~ Total Residual Chlorine. mzlL •• NA •• Weekly Grab " , , I I [lH. S.u. NA NA 6.5-9.0 Weekly
In-situ ,-----Oil and Grease. mglL ~ , NA I 10 Weekly Visual I 'Class I Cold Class /Warm Class 2 Cold and Warm Maximum .?_OO_C~ _ _ '_I Maximum 30°C Monitor g. Facilities discharging
hydrostatic test water from the testing of new or used pipes. tanks. or other similar vessels shall comply with the following limitations unless the Division imposes additional monitoring.
See the facility certification for a complete list a/parameters and limitations. (I) New Pipes, tanks, or other similar vessels shall use the ollowin limitations: i Discharge Limitations
Effluent Parameter Daily F,equency Sample Type , Flow. g[lm NA Instantaneous ~.-, Total Sus ended Solids. m IL 45 Grab c_ _ "r.coo"t.a /. ~R..e " c",o"-ve",r-"a'Ob",le7"lr."o. .n." -.
,,-m=L'O--+-,=:.:"-,-+--,;Nc:A,--+=~"-i' Twice per Discharge .~ ___-,G~r,-,a".b,;--____~ , Total Residual Chlorine. mglL NA Grab ____ , pH. s.u. __ o-_~--,;Nc-A:-+I--,;Nc:A':--r-'6"-'),,;---;;9,-,.0'
--l In-situ Oil and Grease. mglL NA .L NA 10 Visual (2) Used Pipes. tanks. or other similar vessels shall use the ollowin limitations: I, Discharge Limitations i 30 Day I 7 Day i Daily
I, Ave. I, Ave I max I i Total Recoverable Iron. m!!IL I Report NA i Report I Effluent Parameter ---c=----c~-,F.'Cl'-"o"'w". . .,g;t;p"m';-,-,--_c:--c--,R. .e" ,p"o",rt'-., NA , Re[lort
Total Suspended Solids ~L' 30 45 . I NA i Chemical Oxveen Demand. melL: Report NA i Report , '--L0tal Residual Chlorine. mgiL I *. NA •• i Total BTEX. mzlL NA NA , 0.1 Benzene, mglL
0.001 NA Report I " ----~ , __ EH. s.u. NA NA 6.5-9.0 I ~-L___ Ot! and Grease. mgiL NA I NA i 10 Frequency SampJeType Instantaneous Grab I Grab I Grab Twice per Discharge 1--: ------'G"'-ra"b"-------
" I Grab ------~~~------~ Grab In-situ Visual h. Discharges from facilities that employ the super chlorination (50-500 mgiL) of potable water lines for the diSinfection of these lines
in a routine or planned situation and wish to discharge the e.f!luent shall comply with the follOWing limitations unless the Division imposes additional monitoring. See the facility
certification for a complete list of parameters and limitations. Discha, e Limitations Effluent Pa,amete, , 30 Day 7 Day', Daily I Ave. Ave max, 1 Frequency Sample Type
COLORADO DEPARTMENF OF PUBUC HEALTH AND ENVIRONMENF, Water Quality Control Division Rarionale . Page 4, Permit No. COG~6()())O() i. Facilities discharging wastewaters other than the
types listed above when negligible pollution concerns are present shall comply with the/allowing limitations unless the Division imposes additional monitoring. See the/acility certification/or
a complele 1i~1 o/parameters and limitations. i Discharge Limitations EjJluent Parameter . 30 Day ! 7 Day I Daily Frequency Sample Type ~ __ ~. ____ _ I Ave. i Ave i max ! i ~._ Flow,
Rpm ..J..Iieport! NA t Report , :l Instantaneous I Total Suspended Solids, mglL i 30 ! 45 I NA I Tw-D' h I Grab ----oil and Grease, mglL .UA ~r--~ Ice per ISC. arge! Visual. ---Turbidi
NA NA Visual j. Facilities discharging wastewater from the washing of root crops such as potatoes, onions, sugar beets, or other fruit/vegetable agricultural produce or any other facility
that discharges wash water associated with vegetative wastes shall comply with the following limitations unless the Division imposes additional monitoring, See the facility certification
for a complete list ofrarameters and limitations. i Dischar e Limitations EjJluent Parameter I 30 Day 7 Day I Daily i. Frequency Sample Type -' Flow, gpm i RAevpeo,r t II Ave Max j I
i I Total Suspended Solids, mglL I 30 I r;:-:--;---I 30 I 'l!Jt'Iogicai Oxygen Demand, mglL . {'H, S.u. I NA ftecal coliform Bacteria, #/100 ml! NA i ___ (JtI and Grease, mglL •• See
Partl.B.2. of the permit. I NA I Report 45 NA I 45 J ReportL NA I 6.5-9.0 I NA •• i Weekly Monthly I Monthly Weekly. i Weeki)'. ! , Instantaneous Grab Grab In-situ Grab Christopher L.
Gates March 07, 200 I ~omments made by City and County of Denver, Department of Environmental Health. Environmental Health Division: Note: "EPD" refers to this department making the
following comments). lational Minimal Discharge General Permit In Colorado >age2 E. b. "Include discharges of wastewater from the washing 0/open area patios and malls, and under effluent
parameters add Fecal coliform and E. coli bacteria. We believe that some elevated bacteria levels that EPD has seen through our monitoring program may be a result of the washing of open
seating patio areas as a result of food stuffs and animal wastes. The timing of the peaks and ebbs as well as surveillance o/the area has lead to this preliminary conclusion. " he DhJision
made the following changes: Fecal coliform and E. Coli were added to the list of parameters in part E. b. of the rationale. d. "Under effluent parameters, add nitrate. EPD's monitoring
program indicates that temporary animal holding areas may be contributing to elevated nitrate loading at storm sewer out/ails. EPD believes our monitoring data is indicative of what
could occur throughout the state . .. 'e Division made the/ollowing changes: Nitrate-Nitrogen (NO,) was added to list of parameters in Part E. do/the rationale. e. "EPD does not believe
that mobile washers should be permi/led to directly discharge to state waters. Out 0/the 47 Minimal Discharge Certifications that EPD has received, twelve have been/or mobile or "pressure
washers." These certifications allow for discharge from "a variety of locations" that may be inclusive of the Denver Metro Area or the entire Front Range. EPD has also received various
compliance notifications that the Water Quality Control Division (WQCD) has issued to a number of these permit holders ranging from delinquent DMRs (the most common) 10 an !
COWRADO DEPARTMENT OF PUBUC HEALTH AND ENVIRONMENT. Warer Quality Conlrol Division RaJionaie -Page 5, Permi! No. COG-6(X)()()() issued Notice of Violation. The broad scope of these certifications
do not allow for regulatory oversight from the WQCD or any local health agency and Ihe effectiveness of "selfmonitoring" is suspect. EPD also recommends that Ihe application for certification
include a broader assessment a/various environmental factors that could adversely impact groundwater discharges from foundation. basement, underground structure dewatering, or well water
pump tests. In addition to the question concerning landfills we would recommend that entities be required to conduct the same "due diligence" review as necessary for a phase I environmental
audit. " The Division made the following changes: The inclusion of "power washing" and operations related to it were taken out of the Part E. e. of the rationale. Page 3 h. "EPD recommends
the inclusion offire department hose lesting due to the area of high pressure associated with the testing olthe equipment. as well as, the chlorine residual that may be present in the
water. " The Division made the following comments: This area will be covered in another general permit, COG 380000, Treated Water Distribution Systems . .. Page 4 ;. "Under effluent
parameters. add Fecal coliform bacteria. Since agricultural produce is grown in an environment that may utilize animal waste as a/ertilizer, it would seem logical to include this/or
monitoring purposes. " The Division made the following changes: Fecal coliform was added 10 Part E. j. of the rationale. cDPS General Permit '4inimal Discharge Under The Colorado Discharge
Permit System "Coverage Under This Permit I. Types of wastewater a. include open area seating. h. include fire department hose testing. 2. Criteria a. include other sources of contamination.
b. clarifY the distance of downstream drinking water intakes or fisheries. " 'he Division made the following changes and comments: Open area seating was added to Part I.A. l,a., of the
permit. As stated before, the re department hose testing (Pari I A. I.h.) will be addressed in another general related to treated water distribution, so this item need not be ddressed.
The language was expanded to indude other sources of contamination, and a clarification of a distance of 5 miles for any rinking water or fishery downstream (Part lA.2.a. and b.). age
4 3. "Application I. EPD recommends that the application include a "Proof of Authorization" from the owner of the system. The City and County of Denver prohibit some of the discharges
listed under Types of wastewater, and believe that the application and permit should ref/ect county specific prohibitions. " Ie Division made the following changes and comments: Language
was added 10 Part lA.3, i. to include written permission of the authority I}o owns the storm sewer be provided in the case where the discharge may enter a storm sewer.
COWRADO DEPARTMENJ' OF PUBUC HEALTH AND ENVIRONMENT. Water Quality Controt Division Rationale· Page 6, Permit No. COG-600000 Page 16 B. "Terms and Conditions J. General Limitations h.
include; or other material spilled 10 the ground c. The use of biodegradable chemicals elevates the BOD, which can then result in decreased dissolved oxygen levels in the receiving walers.
EPD recommends that if the Dillision approves the use 0/chemicals, the certification ref/ecl appropriate effluent and ins/earn monitoring requirements. g. include portable toilet facilities.
II. Removed Substances include "and applicable local regulations . .. The Division made the following changes and commen/s: Language was added to Part I.B.I.b. to include "spilled material."
In Part lB. I. c., EPD wanted the approval of certain biodegradable chemicals used. This has always been a condition of the permit as to review Material Safety Data Sheets (MSDS) of
chemicals used regardless of their biodegradability. Limits are appliedfor BOD, in the certification, and it is the responsibility of the permit holder to meet those limits. In Part
lB.I.g., portable toilet facilities was added to the paragraph. "Removed Substances" in Part II.A.II. had added language /0 include local agencies in the procedures for disposing of
solids, sludges, and other Do//uran/s. Christopher L. Gates March 8, 2001