Document K6pmr38JkObqVexYe4eE2qapw

Inspection Entry Date/Time Inspection Exit Date/Time Regulatory Program Type of Inspection EPA REGION 10 Enforcement Division INSPECTION REPORT 09/11/2023 06:50 AM (AKT) Announced: Yes 09/11/2023 04:38 PM (AKT) Access: Granted RCRA Compliance Evaluation Inspection (CEI) Company Name Facility or Site Name Facility/Site Identifier Facility/Site Physical Address City, State, Zip Code County/Borough Generator Status NAICS Type of Operation Geographic Coordinates Mailing Address/Secondary Address City, State, Zip Code Coeur Alaska, Inc. Coeur Alaska, Inc. - Kensington Gold Mine AKR000203612 Sec 5, T35s, R62e Approx 45 Mi Juneau, AK 99801 Juneau City & Borough Large Quantity Generator (LQG) 21222 Gold Ore and Silver Ore Mining 58.303379, -134.407654 Mr. Peter Strow, Environmental Manager pstrow@coeur.com 3031 Clinton Drive, Suite 202 Juneau, AK 99801 CC: Ms. Cassandra Joos, Senior Environmental Coordinator cjoos@coeur.com Ms. Sierra Lammers, Environmental Coordinator slammers@coeur.com Juneau, AK 99801 Permit Number (If Applicable) Not Applicable Lead Inspector: Jon Jones EPA Region 10 Jones.Jon@epa.gov (907) 271-6329 Supervisor Review: Matt Quarterman EPA Region 10 Quarterman.matthew@epa.gov (206) 553-2146 SECTION I - INTRODUCTION Site Entry and Purpose of the Inspection Type of inspection: Compliance Evaluation Inspection (CEI) EPA Region 10 Lead Inspector, Jon Jones, arrived at the Coeur Alaska, Inc Kensington Gold Mine Facility (the 1 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 "Site" or "Facility"), located at Sec 5, T35s, R62e Approx 45 Mi, Juneau, AK 99801, at 06:50 AM (AKT) on 09/11/2023 for an announced inspection. EPA Region 10 Lead Inspector presented credentials to and informed Ms. Cassandra Joos, Senior Environmental Coordinator that this was an EPA Region 10 inspection to determine compliance with Resource Conservation and Recovery Act (RCRA). This was a Resource Conservation and Recovery Act (RCRA) inspection. The facility was inspected to ensure compliance with standards for hazardous waste generators and universal waste management (40 C.F.R. Part 262 through 273) and used oil management (40 C.F.R. Part 279). The inspection was conducted as part of a Core Program requirement for FY 2023. This report is based on information supplied by Coeur Alaska, Inc. - Kensington Gold Mine Facility representatives, observations made by the EPA Region 10 inspector, and records and reports maintained by the facility, but not limited to: direct observations made by the EPA Region 10 Inspector(s), photographs taken by EPA Region 10 inspector(s), physical evidence collected by the EPA Region 10 inspector(s), measurements or samples taken by EPA Region 10 inspector(s), verbal or written statements made by information supplied by the facility representatives during or subsequent to the on-site Inspection, and materials, processes, data, photographs, or documents shown, demonstrated, or submitted to the EPA Region 10 inspector(s) by the facility representatives during or subsequent to the on-site Inspection. In addition, information gathered prior to or subsequent to the Inspection from a review of USEPA, State, and public records may be included in this report. Attendees Title/Organization Name Phone Lead Inspector/EPA Jon Jones REGION 10 (907) 2716329 Senior Environmental Coordinator/Coeur Alaska, Inc. Kensington Mine Cassandra Joos (907) 5233606 Environmental Sierra Lammers (907) 523- Coordinator/Coeur 3337 Alaska, Inc. - Kensington Mine RCRA Inspector/ADEC Alan Pefley (907) 2694567 RCRA Inspector/ADEC Emily Vannortwick Email Jones.Jon@epa.gov cjoos@coeur.com Opening Conf. Closing Conf. Yes Yes Yes Yes slammers@coeur.com Yes Yes alan.pefley@alaska.gov Yes Yes emily.vannortwick@alaska.gov Yes Yes Opening Conference At the beginning of the opening conference, I presented Ms. Joos with a list of questions that was part of an information request for mines operating in Alaska. The list of questions presented to Ms. Joos and the facility responses to those questions are included in the attached document log. The file size of the majority of supporting documentation that was received from the facility was too large to be uploaded to the attached Document Log. We asked Ms. Joos about any changes that had taken place since the last inspection. She told us that Kevin Eppers, the last Environmental Manager, had taken another position at one of Coeur's other mines. She told us that Peter Strow was hired to replace Mr. Eppers as the new Environmental Manager at the Kensington Mine. Ms. Joos told us that Mr. Strow would not be available for the inspection, as he was away on a two-week moose hunt. Ms. Joos also told us that the Julian Mine was closed in May/June 2023 and that they have flooded the mine. 2 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 She also said that they had updated their Forrest Service Plan in February 2022. The mine is located on patented claims within the Tongass National Forest and portions of the support operations are located on U.S. Forest Service Lands. During the opening conference, we explained that the focus of the RCRA inspection was to identify types of wastes generated, points of waste generation, methods of waste management, and review relevant documents. Only those areas in which we observed areas of concern or noted other pertinent issues are discussed in this inspection report. Facility/Site Information The following information was obtained from the facility's website (https://www.coeur.com/operationsprojects/kensington-ak/default.aspx) as well as the Alaska Department of Natural Resources website (https://dnr.alaska.gov/mlw/mining/large-mines/kensington/). Coeur Alaska's Kensington mine is an underground gold operation located in southeast Alaska, consisting of the Kensington Main deposit, Raven deposit as well as other nearby deposits and exploration targets. The Kensington mine is housed in the historic Berners Bay Mining District which has seen over 130 years of resource development. The Kensington mine is located 45 miles north-northwest of Juneau and 35 miles south-southeast of Haines. The mine has a small footprint of approximately 240 acres and is accessed via the water on Lynn Canal or by air. The project is operated by Coeur Alaska, Inc. (Coeur), a wholly owned subsidiary of Coeur Mining. The major Kensington Mine facilities include the Kensington underground mine, underground paste backfill plant, surface mill, tailings treatment facility, administrative and camp facilities, generator facilities, water treatment facilities, and marine dock facility. Power is supplied by on-site diesel generators. Coeur Alaska employs approximately 400 mining professionals at the mine and is the second largest private employer and the second largest property taxpayer in the City and Borough of Juneau. The mine was originally permitted in 2005, and operates 24-hours a day, 365 days a year. Coeur Alaska became involved in the Kensington mine property and formed a joint venture in 1987, and in 1995, Coeur Mining acquired 100% interest in the mine. Commercial production commenced in 2010 and in 2019, Kensington achieved over one million ounces of gold produced. In 2021, approximately 604,753 tons of ore was mined, and 673,625 tons were processed through the mill facility. Approximately 16,671 tons of concentrate were shipped to an off-site refinery producing approximately 123,550 ounces of gold. A total of 187,029 feet of core drilling was completed in 2021. The drilling was comprised of production and exploration programs. Number of employees ~395 Length of Facility at Location Production began in 2010 Operating Hours The Mine operates 24 hours a day - 7 days a week with two 12-hour shifts. Mine employees typically work 2 weeks on and 1 week off, with approximately a third of the employees out at any given time. Safety Training Yes Provided to Inspector(s)? Size of Facility 240 acres What type of generator facility notified? Large Quantity Generator (LQG) 3 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 What type of generator facility verified as? Weather Conditions Verified by Ms. Joos to be an LQG Rainy Process Description According to Ms. Joos, wastes generated at the facility include waste aerosol cans, waste residue from aerosol can puncturing, waste aerosol puncture filters, waste lead contaminated debris (PPE, cupels, crucibles, slag, plastic bags, and clean-up cloths), waste sodium hydroxide cleaner, waste ammonium vacu-vial water quality test kits, used oil, used oil filters, and used antifreeze. We were accompanied throughout the inspection by Ms. Lammers and Ms. Joos. During the inspection we looked at the facility's processes, in addition to hazardous waste management practices, generation points, and accumulation areas. We looked for wastes that facility representatives had not yet identified or designated as hazardous. We also observed the facility's universal waste and used oil management. Building(s) Building/Area/Sub-area Assay Lab Area just outside the lab Central Accumulation Area (CAA) Green Connex adjacent to CAA accumulation locker Comet Mine Water Treatment Plant (MWTP) Flammable storage cabinet Concentrate Load Out Mill Maintenance/Mill Small bead-blast booth Sewage Treatment Plant Lab Surface Maintenance Shop Area outside and adjacent to the Surface maintenance Shop Oil filter crusher Parts Room Tailings Treatment Facility (TTF) Filter Press Underground Maintenance 940 Paste Plant Underground Maintenance at the 900 Main Underground Maintenance Shop 850 Process Description Staging area for containers of used crucibles and gold bar slag. Accumulation of hazardous waste. Additional CAA containment area. Used to clean up parts removing rust/scale. Universal waste battery accumulation area. Crushing of used oil filters. Equipment and parts storage. Filter Press sludge generated in the TTF. 4 of 36 Area of Concern Yes Yes Yes Yes Yes Yes No No No No Yes Yes Yes Yes No No Yes Yes No Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 Universal Waste Connex Storage Connex used to accumulate universal No wastes. Warehouse Storage of mining equipment and supplies to be Yes issued to mine personnel. Satellite Accumulation Area (SAA), SAA for the accumulation of waste aerosol can Yes outside and adjacent to the warehouse residue in a container with an attached aerosol can popper. Water Treatment Plant (WTP) No SECTION II - OBSERVATIONS Building: Tailings Treatment Facility (TTF)/Filter Press Observation #: JJ1-OB-001 Date: 09/11/2023 Person Interviewed: Cassandra Joos Contains AOC: No Contains CBI: No Title: Senior Environmental Coordinator While in the Tailings Treatment Facility, we saw a filter press where sludge was generated from the treatment process and claimed by the facility to be managed under the Bevill exemption. Photo(s) 1. IMG_1640.jpg 2. IMG_1641.jpg 3. IMG_1642.jpg Building: Warehouse/Satellite Accumulation Area (SAA), outside and adjacent to the warehouse Observation #: JJ1-OB-002 Date: 09/11/2023 Contains AOC: Yes Contains CBI: No Person Interviewed: Cassandra Joos Title: Senior Environmental Coordinator During the inspection, we saw a SAA for the accumulation of waste aerosol residue. The SAA was located outside and adjacent to the Warehouse. At the time of the inspection, Ms. Joos explained that when a waste aerosol can was generated by mine personnel in the area, they would bring the aerosol can to the SAA and puncture the aerosol in the can popper that was attached to the SAA container. The punctured aerosol can is then placed into a lined container and when full the punctured aerosol cans are managed as scrap metal. While inspecting this SAA, we observed quite a bit of overspray in the area from the aerosol can puncturing process. There was overspray on the surrounding walls of the SAA as well as paint that had run down the side of the 55-gallon SAA container and on the cover of the puncturing device. Later, while reviewing the photos, I noticed that at the time of the inspection the closure device on the attached aerosol can popper was not closed down onto the cover of the puncturing device so the SAA container was not closed during the inspection. Ms. Joos response, that was received following the inspection, included a list of "Items noted during the inspection update" that included the following language: EPA and ADEC Inspectors noted the following items during the inspection and close out meeting that are still in process of determination or correction. Overspray was noted in one of the aerosol can puncture units. We were unable to determine where the overspray was coming from but decided the best management practice would be to change the 5 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): puncturing device. Photo(s) 1. IMG_1643.jpg 2. IMG_1644.jpg 09/11/2023 - 09/11/2023 Building: Warehouse Observation #: JJ1-OB-003 Date: 09/11/2023 Person Interviewed: Cassandra Joos Contains AOC: Yes Contains CBI: No Title: Senior Environmental Coordinator During the inspection, we asked Ms. Joos about the facility's use of leather products, such as gloves and mine belts. I explained that waste leather gloves will fail for chromium (D007) when tested. Ms. Joos indicated that she was unaware of this. I asked Ms. Joos if they issued these leather items to facility personnel, and she said these items were issued out of the Warehouse. When we got to the Warehouse, supply personnel took us to where they store these leather products. While there we saw a plastic sleeve on the bottom shelf that, according to the label, held 10 pair of leather gloves. We also saw some of the mining belts that are used to carry self-contained breathing devices. I explained that the belts may also have leather components. I explained that the facility would be required to make a waste determination for their facility's waste leather. Ms. Joos response, that was received following the inspection, included a list of "Items noted during the inspection update" that included the following language: EPA and ADEC Inspectors noted the following items during the inspection and close out meeting that are still in process of determination or correction. Leather items, goods may fail TCLP. Has a waste determination been completed on leather gloves or other PPE? Coeur Alaska has created a list of all leather goods and PPE that may be ordered. Waste determination of those items is in process. This list of "Items noted during the inspection update" is included in the document log of this report. Photo(s) 1. IMG_1645.jpg 2. IMG_1646.jpg 3. IMG_1647.jpg Building: Surface Maintenance Shop/Area outside and adjacent to the Surface maintenance Shop Observation #: JJ1-OB-004 Date: 09/11/2023 Contains AOC: Yes Contains CBI: No Person Interviewed: Cassandra Joos Title: Senior Environmental Coordinator While walking up to the Surface Maintenance Shop, we saw a blue, 55-gallon poly container that was being used to accumulated sealed, lead-acid battery jump packs. We asked Ms. Joos about the batteries, and she told us that they manage the batteries as universal waste. The container was labeled with the words "Jump Pack Collection Drum" and was marked with a DOT label for corrosivity. At the time of the inspection, the 55-gallon container held one sealed, lead-acid battery jump pack and was not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." Ms. Joos response, that was received following the inspection, included photo documentation showing that the 6 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): container had been marked with a "Used Batteries" label after the inspection. Document(s) 1. Jump Pack Battery Drums Labels.pdf Photo(s) 1. IMG_1648.jpg 2. IMG_1649.jpg 09/11/2023 - 09/11/2023 Building: Surface Maintenance Shop/Oil filter crusher Observation #: JJ1-OB-005 Date: 09/11/2023 Person Interviewed: Cassandra Joos Contains AOC: Yes Contains CBI: No Title: Senior Environmental Coordinator While inspecting the Surface Maintenance Shop, we saw a used oil filter crusher. Upon closer inspection, we saw a five-gallon container beneath the filter crusher that was being used to accumulate used oil as filters were being crushed. We looked inside the container and saw that it contained used oil. At the time of the inspection, the container was approximately 1/4 full, containing a little more than a gallon of used oil, and was not labeled with the words "Used Oil." Ms. Joos response, that was received following the inspection, included a list of "Items noted during the inspection update" that included the following language: EPA and ADEC Inspectors noted the following items during the inspection and close out meeting that are still in process of determination or correction. Containers determined to have held or the potential to hold used oil without used oil labeling or very faded labeling. Mobile maintenance personnel have been have reminded by supervisory personnel to label all used oil containers. The next online training module will contain reminder information concerning labeling of all used oil containers. This list of "Items noted during the inspection update" is included in the document log of this report. Photo(s) 1. IMG_1650.jpg 2. IMG_1651.jpg 3. IMG_1652.jpg 4. IMG_1653.jpg 5. IMG_1654.jpg Building: Surface Maintenance Shop/Parts Room Observation #: JJ1-OB-006 Date: 09/11/2023 Person Interviewed: Cassandra Joos Contains AOC: Yes Contains CBI: No Title: Senior Environmental Coordinator While inspecting the Surface maintenance Shop, we saw another waste lead-acid battery jump pack on the floor in the Parts Room. The battery had a tag attached to it that was marked with the word, "Junk." Ms. Joos verified that it was a waste battery jump pack that should be managed as universal waste. At the time of the inspection, the waste battery jump pack was not labeled with either the phrase "Universal Waste - Batteries," 7 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 "Waste Batteries," or "Used Batteries." Ms. Joos response, that was received following the inspection, included photo documentation showing that the waste lead-acid battery jump pack had been placed inside the container outside that had since been labeled as "Used Batteries." Document(s) 1. Jump Pack Battery Disposal.pdf Photo(s) 1. IMG_1655.jpg 2. IMG_1656.jpg Building: Assay Lab/Area just outside the lab Observation #: JJ1-OB-007 Date: 09/11/2023 Person Interviewed: Cassandra Joos Contains AOC: Yes Contains CBI: No Title: Senior Environmental Coordinator While inspecting the Assay Lab, we saw two 55-gallon containers that were staged just right outside the door to the lab. According to facility/lab personnel, one 55-gallon container held used crucibles that had been onsite since November 2022. The other 55-gallon container held gold bar slag that had been onsite for two months. According to facility/lab personnel, they have been waiting to hear whether the contents of the containers will be managed as waste or if it will go through further extraction to get out any remaining gold, silver, or lead. I explained that a waste determination was required to be made at the point of generation. At the time of the inspection, the facility had not made a hazardous waste determination on either the used crucibles or the slag. Ms. Joos response, that was received following the inspection, included a copy of an invoice showing that the used crucibles and gold bar slag had been sold. Document(s) 1. Gold Slag Material Sale.pdf Photo(s) 1. IMG_1657.jpg 2. IMG_1658.jpg 3. IMG_1659.jpg 4. IMG_1660.jpg Building: Central Accumulation Area (CAA) Observation #: JJ1-OB-008 Date: 09/11/2023 Person Interviewed: Cassandra Joos Contains AOC: Yes Contains CBI: No Title: Senior Environmental Coordinator During the inspection, we went across the road from the Assay Lab to inspect the facility's CAA. The facility uses a large metal HAZMAT storage locker for the accumulation of hazardous waste. Upon opening the doors of the CAA, we saw a five-gallon poly container containing hazardous waste that was not closed. The container held waste test kits for ultra-low chlorine. At the time of the inspection, the lid on the container was not snapped down all the way, making a complete seal with the container. Ms. Joos snapped the lid down completely during the inspection, closing the container. 8 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): Photo(s) 1. IMG_1662.jpg 2. IMG_1663.jpg 09/11/2023 - 09/11/2023 Building: Central Accumulation Area (CAA)/Green Connex adjacent to CAA accumulation locker Observation #: JJ1-OB-009 Date: 09/11/2023 Contains AOC: Yes Contains CBI: No Person Interviewed: Cassandra Joos Title: Senior Environmental Coordinator While still at the CAA, we saw a large green Connex box, adjacent to the large HAZMAT storage locker, that was also being used as a CAA. The Connex had signage posted on the door that stated, "Non-Hazardous Waste Storage Room." When we entered the Connex, we saw that there were two 55-gallon containers and one 35gallon container of hazardous waste being accumulated inside. At the time of the inspection, we saw a 55gallon container that was labeled as containing waste amines (D002). Additional labeling indicated that it contained a Part B hardener. Upon closer inspection, we saw that there was no accumulation start date (ASD) marked on the container. Ms. Joos marked the container with an ASD of 9/2/23 during the inspection. Photo(s) 1. IMG_1666.jpg 2. IMG_1664.jpg 3. IMG_1668.jpg 4. IMG_1669.jpg 5. IMG_1665.jpg 6. IMG_1667.jpg Building: Mill Maintenance/Mill/Small bead-blast booth Observation #: JJ1-OB-010 Date: 09/11/2023 Person Interviewed: Cassandra Joos Contains AOC: No Contains CBI: No Title: Senior Environmental Coordinator While in the Mill Maintenance area, we saw a small bead-blast booth. We asked Ms. Joos if waste was ever generated from this process and how it was managed. At the time of the inspection, Ms. Joos told us that she would need to find out and get back with us. Ms. Joos response, that was received following the inspection, included a list of "Items noted during the inspection update" that included the following language: EPA and ADEC Inspectors noted the following items during the inspection and close out meeting that are still in process of determination or correction. Sand Blasting Units and Sandblasting materials. Has a waste determination been completed for sand blasting materials? There is just one sand blasting unit at Kensington Mine. The material used in the sand blast unit is nonhazardous by the SDS. A sample of used sand blast material is in process of being collected and analyzed. Another sample will be collected and analyzed when the material currently in the unit is ready 9 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 to be disposed as defined by the maintenance personnel using the sand blaster. This list of "Items noted during the inspection update" is included in the document log of this report. Building: Comet Mine Water Treatment Plant (MWTP)/Flammable storage cabinet Observation #: JJ1-OB-011 Date: 09/11/2023 Contains AOC: Yes Contains CBI: No Person Interviewed: Cassandra Joos Title: Senior Environmental Coordinator While inspecting the Comet Mine WTP, we opened a flammable storage cabinet. Once opened, we saw an assortment of products being used at the WTP including aerosol cans. We checked some of the aerosol cans in the storage cabinet, by shaking them, to determine if any were empty/waste aerosol cans. While checking the various aerosol cans in the cabinet, we identified one waste aerosol that was still pressurized and contained some material. Ms. Joos confirmed that the aerosol can was a waste aerosol can. At the time of the inspection, the waste aerosol can was not labeled with the words "Hazardous Waste" or marked with a hazard indicator. Ms. Joos took the waste aerosol can with her when we left the WTP, and she punctured the aerosol can in a waste aerosol SAA during the inspection. Photo(s) 1. IMG_1672.jpg Building: Underground Maintenance at the 900 Main Observation #: JJ1-OB-012 Date: 09/11/2023 Person Interviewed: Cassandra Joos Contains AOC: Yes Contains CBI: No Title: Senior Environmental Coordinator While inspecting the UG 900 Maintenance area, we saw two large used oil drain pads that contained used oil and were not labeled with the words "Used Oil." It could be seen that at one time the pads had been labeled, but the markings needed to be refreshed as the words were faded and/or obscured to the point that the words were illegible. Ms. Joos response, that was received following the inspection, included a list of "Items noted during the inspection update" that included the following language: EPA and ADEC Inspectors noted the following items during the inspection and close out meeting that are still in process of determination or correction. Containers determined to have held or the potential to hold used oil without used oil labeling or very faded labeling. Mobile maintenance personnel have been have reminded by supervisory personnel to label all used oil containers. The next online training module will contain reminder information concerning labeling of all used oil containers. This list of "Items noted during the inspection update" is included in the document log of this report. While still in the UG Maintenance area, we saw a 55-gallon poly container that held a waste lead-acid battery jump pack. At the time of the inspection, the container was not labeled with either phrase "Universal Waste - 10 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): Batteries," "Waste Batteries," or "Used Batteries." Photo(s) 1. IMG_1675.jpg 2. IMG_1674.jpg 3. IMG_1676.jpg 4. IMG_1673.jpg 09/11/2023 - 09/11/2023 Building: Underground Maintenance 940 Paste Plant Observation #: JJ1-OB-013 Date: 09/11/2023 Person Interviewed: Cassandra Joos Contains AOC: Yes Contains CBI: No Title: Senior Environmental Coordinator While inspecting the 940 Paste Plant, we saw a 55-gallon SAA container with an attached aerosol can popper. At the time of the inspection, the SAA container contained hazardous waste, but the cover on the attached aerosol can popper was not closed; therefore, the container was not closed. Ms. Joos closed the cover on the attached aerosol can popper during the inspection. Photo(s) 1. IMG_1677.jpg 2. IMG_1678.jpg SECTION III - RECORDS REVIEW Record: Contingency Plan's Quick Reference Guide Ref #: JJ1-RR-001 Reviewed By: Jon Jones AOC: No Reviewed Date: 09/11/2023 At the time of the inspection, Ms. Joos told us that the facility did not have a Contingency Plan Quick Reference Guide. Ms. Joos response, that was received following the inspection, included a Contingency Plan Quick Reference Guide. Record: Inspections AOC: Yes Ref #: JJ1-RR-002 Reviewed By: Jon Jones Reviewed Date: 09/11/2023 During the inspection, we reviewed the last three years of the facility's weekly hazardous waste inspections, covering the period of September 11, 2020, through September 11, 2023. During this review, we found that no weekly hazardous waste inspection was conducted for the following two weeks: 3/13/22 through 3/19/22 4/9/23 through 4/15/23 Ms. Joos response, that was received following the inspection, included photo documentation of a note pad that she stated shows an inspection was completed on 3/16/22, during the week of 3/13/22 through 3/19/22. Document(s) 11 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 1. Storage Room Inspections Dates.pdf SECTION IV - AREA OF CONCERN The presentation of Area(s) of Concern does not constitute a formal compliance determination or violation. Building: Warehouse JJ1-OB-002 Area: Satellite Accumulation Area (SAA), outside and adjacent to the warehouse Sub-area: At the time of the inspection the closure device on the attached aerosol can popper was not closed down onto the cover of the puncturing device so the SAA container was not closed during the inspection. Regulation: Sections: Building: Warehouse JJ1-OB-003 Area: Sub-area: During the inspection, we asked Ms. Joos about the facility's use of leather products, such as gloves and mine belts. I explained that waste leather gloves will fail for chromium (D007) when tested. Ms. Joos indicated that she was unaware of this. I asked Ms. Joos if they issued these leather items to facility personnel, and she said these items were issued out of the Warehouse. When we got to the Warehouse, supply personnel took us to where they store these leather products. While there we saw a plastic sleeve on the bottom shelf that, according to the label, held 10 pair of leather gloves. We also saw some of the mining belts that are used to carry self-contained breathing devices. I explained that the belts may also have leather components. I explained that the facility would be required to make a waste determination for their facility's waste leather. Regulation: Sections: Building: Surface Maintenance Shop Area: Oil filter crusher Sub-area: 12 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 JJ1-OB-005 At the time of the inspection, the container was approximately 1/4 full, containing a little more than a gallon of used oil, and was not labeled with the words "Used Oil." Regulation: Sections: Building: Surface Maintenance Shop Area: Parts Room JJ1-OB-006 Sub-area: We saw a waste lead-acid battery jump pack on the floor in the Parts Room. The battery had a tag attached to it that was marked with the word, "Junk." Ms. Joos verified that it was a waste battery jump pack that should be managed as universal waste. At the time of the inspection, the waste battery jump pack was not labeled with either the phrase "Universal Waste Batteries," "Waste Batteries," or "Used Batteries." Regulation: Sections: Building: Surface Maintenance Shop Area: Area outside and adjacent to the Surface maintenance Shop JJ1-OB-004 Sub-area: At the time of the inspection, the 55-gallon container held one sealed, lead-acid battery jump pack and was not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." Regulation: Sections: Building: Assay Lab JJ1-OB-007 Area: Area just outside the lab Sub-area: At the time of the inspection, the facility had not made a hazardous waste determination on either the used crucibles or the slag. Regulation: Sections: Building: Central Accumulation Area Area: (CAA) JJ1-OB-008 Sub-area: 13 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 Upon opening the doors of the CAA, we saw a five-gallon poly container that was not closed. The container held waste test kits for ultra-low chlorine. At the time of the inspection, the lid on the container was not snapped down all the way, making a complete seal with the container. Regulation: Sections: Building: Central Accumulation Area Area: Green Connex adjacent to CAA Sub-area: (CAA) accumulation locker JJ1-OB-009 The Connex had signage posted on the door that stated, "NonHazardous Waste Storage Room." When we entered the Connex, we saw that there were two 55-gallon containers and one 35-gallon container of hazardous waste being accumulated inside. At the time of the inspection, we saw a 55-gallon container that was labeled as containing waste amines (D002). Additional labeling indicated that it contained a Part B hardener. Upon closer inspection, we saw that there was no accumulation start date (ASD) marked on the container. Regulation: Sections: Building: Comet Mine Water Treatment Plant (MWTP) JJ1-OB-011 Area: Flammable storage cabinet Sub-area: While inspecting the Comet Mine WTP, we opened a flammable storage cabinet. Once opened, we saw an assortment of products being used at the WTP including aerosol cans. We checked some of the aerosol cans in the storage cabinet, by shaking them, to determine if any were empty/waste aerosol cans. While checking the various aerosol cans in the cabinet, we identified one waste aerosol. Ms. Joos confirmed that the aerosol can was a waste aerosol can. At the time of the inspection, the waste aerosol Regulation: 14 of 36 Sections: Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): can was not labeled with the words "Hazardous Waste" or marked with a hazard indicator. Building: Underground Maintenance Area: at the 900 Main JJ1-OB-012 While inspecting the UG 900 Maintenance area, we saw two large used oil drain pads that contained used oil and were not labeled with the words "Used Oil." It could be seen that at one time the pads had been labeled, but the markings needed to be refreshed as the words were faded and/or obscured to the point that the words were illegible. Regulation: Building: Underground Maintenance Area: 940 Paste Plant JJ1-OB-013 While inspecting the 940 Paste Plant, we saw a 55-gallon SAA container with an attached aerosol can popper. At the time of the inspection, the cover on the attached aerosol can popper was not closed; therefore, the container was not closed. Regulation: Record: Inspections JJ1-RR-002 No weekly hazardous waste inspection was conducted for the following two weeks: 3/13/22 through 3/19/22 4/9/23 through 4/15/23 Regulation: 09/11/2023 - 09/11/2023 Sub-area: Sections: Sub-area: Sections: Sections: 15 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 SECTION V - CLOSING CONFERENCE AND FOLLOW UP Closing Conference At the conclusion of the inspection, I conducted a closing conference that was attended by those listed in the Attendees table, in Section I of this report. I thanked everyone for their time and cooperation during the inspection and began a review of the areas of concern (listed in Section III - Areas of Concern) that I observed during my inspection of the facility. I then explained the follow-up process that would take place once I finished the report. I explained they would receive a copy of the report as would a case officer. I told them the case officer would review the report to determine if any of my areas of concern resulted in determinations of violation. SECTION VI - SAMPLING ACTIVITIES AND ANALYTICAL RESULTS No sampling was conducted. SECTION VII - LIST OF APPENDICES 1. Photo Log 2. Document Log 16 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): APPENDIX 1: PHOTO LOG 09/11/2023 - 09/11/2023 [Title] 09/11/2023 09:01 AM No CBI No PII Tailings Treatment Facility (TTF)/Filter Press Close-up view of the filter press. IMG_1640.jpg Photographer: Jon Jones 58.81415833, -135.03846666 [Title] 09/11/2023 09:01 AM No CBI No PII Tailings Treatment Facility (TTF)/Filter Press View of sludge in trough beneath filter press. IMG_1641.jpg Photographer: Jon Jones 58.81414166, -135.03854444 17 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] 09/11/2023 09:04 AM No CBI No PII Tailings Treatment Facility (TTF)/Filter Press View of the filter press in the TTF. IMG_1642.jpg Photographer: Jon Jones 58.81406666, -135.03875833 [Title] IMG_1643.jpg 09/11/2023 09:30 AM No CBI No PII Photographer: Jon Jones Warehouse/Satellite Accumulation Area (SAA), outside 58.83980555, -135.045975 and adjacent to the warehouse View of SAA, showing 55-gallon container of waste aerosol residue with attached aerosol can popper is not closed. 18 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1644.jpg 09/11/2023 09:31 AM No CBI No PII Photographer: Jon Jones Warehouse/Satellite Accumulation Area (SAA), outside 58.84001944, -135.04605 and adjacent to the warehouse Close-up view of the SAA, showing 55-gallon container of waste aerosol residue with attached aerosol can popper is not closed. [Title] IMG_1645.jpg 09/11/2023 09:52 AM No CBI No PII Photographer: Jon Jones Warehouse 58.83957777, -135.04615833 View of a plastic sleeve, holding 10 pair of leather gloves. 19 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1646.jpg 09/11/2023 09:52 AM No CBI No PII Photographer: Jon Jones Warehouse 58.83963333, -135.04611111 Close-up view of the information marked on the sleeve of gloves. [Title] IMG_1647.jpg 09/11/2023 09:55 AM No CBI No PII Photographer: Jon Jones Warehouse 58.83963333, -135.04609722 View of the mining belts that may contain leather components. 20 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1648.jpg 09/11/2023 10:08 AM No CBI No PII Photographer: Jon Jones Surface Maintenance Shop/Area outside and adjacent 58.84078333, -135.04586666 to the Surface maintenance Shop View of a sealed, waste lead-acid battery jump pack inside of a container that is not labeled in a way to indicate it's managed as a universal waste. [Title] IMG_1649.jpg 09/11/2023 10:08 AM No CBI No PII Photographer: Jon Jones Surface Maintenance Shop/Area outside and adjacent 58.84075555, -135.04583611 to the Surface maintenance Shop View of the universal waste battery jump pack container, showing that it's not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." 21 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1650.jpg 09/11/2023 10:13 AM No CBI No PII Photographer: Jon Jones Surface Maintenance Shop/Oil filter crusher 58.8409, -135.04600555 View of the filter crusher, showing the unlabeled container of used oil beneath the crusher. [Title] IMG_1651.jpg 09/11/2023 10:13 AM No CBI No PII Photographer: Jon Jones Surface Maintenance Shop/Oil filter crusher 58.84086944, -135.04571666 Close-up view of the used oil container, showing that it is not labeled with the words "Used Oil." 22 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1652.jpg 09/11/2023 10:13 AM No CBI No PII Photographer: Jon Jones Surface Maintenance Shop/Oil filter crusher 58.840875, -135.04565555 Close-up view of the used oil container, showing that it contains used oil and is not labeled with the words "Used Oil." [Title] IMG_1653.jpg 09/11/2023 10:13 AM No CBI No PII Photographer: Jon Jones Surface Maintenance Shop/Oil filter crusher 58.84109444, -135.04606666 Another view of the used oil container, showing that it is not labeled with the words "Used Oil." 23 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1654.jpg 09/11/2023 10:13 AM No CBI No PII Photographer: Jon Jones Surface Maintenance Shop/Oil filter crusher 58.84108055, -135.04603611 Another view of the container, showing that it holds used oil and is not labeled with the words "Used Oil." [Title] IMG_1655.jpg 09/11/2023 10:24 AM No CBI No PII Photographer: Jon Jones Surface Maintenance Shop/Parts Room 58.8409, -135.04600555 View of a waste lead-acid battery jump pack on the floor in the Part Room. 24 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1656.jpg 09/11/2023 10:24 AM No CBI No PII Photographer: Jon Jones Surface Maintenance Shop/Parts Room 58.8409, -135.04600555 Close-up view of the waste lead-acid battery jump pack, showing that it is labeled as "Junk" and not labeled with either the phrase "Universal Waste - Battery," "Waste Battery," or "Used Battery." [Title] IMG_1657.jpg 09/11/2023 10:46 AM No CBI No PII Photographer: Jon Jones Assay Lab/Area just outside the lab 58.84554722, -135.05026111 View of the 55-gallon container (white lid) holding used crucibles. 25 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] 09/11/2023 10:47 AM No CBI No PII Assay Lab/Area just outside the lab View of the used crucibles in the container. IMG_1658.jpg Photographer: Jon Jones 58.84554722, -135.05026111 [Title] IMG_1659.jpg 09/11/2023 10:51 AM No CBI No PII Photographer: Jon Jones Assay Lab/Area just outside the lab 58.84554722, -135.05026111 View of the 55-gallon container holding the gold bar slag. 26 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1660.jpg 09/11/2023 10:51 AM No CBI No PII Photographer: Jon Jones Assay Lab/Area just outside the lab 58.84554722, -135.05026111 View of the top of the 55-gallon container holding the gold bar slag. [Title] IMG_1662.jpg 09/11/2023 11:03 AM No CBI No PII Photographer: Jon Jones Central Accumulation Area (CAA) 58.84586388, -135.0504 View of five-gallon waste container, shown here with the lid not fully closed. 27 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1663.jpg 09/11/2023 11:10 AM No CBI No PII Photographer: Jon Jones Central Accumulation Area (CAA) 58.84563055, -135.05015555 View of the five-gallon waste container after Ms. Joos closed the container. [Title] 09/11/2023 11:13 AM No CBI No PII Central Accumulation Area (CAA)/Green Connex adjacent to CAA accumulation locker View of the 55-gallon container with the missing ASD. IMG_1664.jpg Photographer: Jon Jones 58.84598055, -135.05046111 28 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1665.jpg 09/11/2023 11:13 AM No CBI No PII Photographer: Jon Jones Central Accumulation Area (CAA)/Green Connex adjacent to CAA accumulation locker 58.84609166, -135.05059722 View of the label on the container, showing that it is not marked with an ASD. [Title] IMG_1666.jpg 09/11/2023 11:13 AM No CBI No PII Photographer: Jon Jones Central Accumulation Area (CAA)/Green Connex adjacent to CAA accumulation locker 58.846175, -135.05073611 View of Ms. Joos marking the ASD of 9/2/23 on the container during the inspection. 29 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1667.jpg 09/11/2023 11:13 AM No CBI No PII Photographer: Jon Jones Central Accumulation Area (CAA)/Green Connex adjacent to CAA accumulation locker 58.84613888, -135.05064444 View of the label showing the ASD of 9/2/23 that was marked on the container by Ms. Joos during the inspection. [Title] 09/11/2023 11:16 AM No CBI No PII Central Accumulation Area (CAA)/Green Connex adjacent to CAA accumulation locker View of the waste from the door of the green Connex. IMG_1668.jpg Photographer: Jon Jones 58.84592777, -135.05052222 30 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1669.jpg 09/11/2023 11:16 AM No CBI No PII Photographer: Jon Jones Central Accumulation Area (CAA)/Green Connex adjacent to CAA accumulation locker 58.84586666, -135.05050555 View of the signage on the door of the green Connex, showing that it is marked "Non-Hazardous Waste Storage Room." [Title] IMG_1672.jpg 09/11/2023 01:03 PM No CBI No PII Photographer: Jon Jones Comet Mine Water Treatment Plant (MWTP)/Flammable storage cabinet [Geographic Coordinates] View of waste aerosol can that was found inside of a flammable storage cabinet. 31 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1673.jpg 09/11/2023 01:38 PM No CBI No PII Photographer: Jon Jones Underground Maintenance at the 900 Main [Geographic Coordinates] Another view of used oil drain pad that is not labeled with the words "Used Oil." [Title] IMG_1674.jpg 09/11/2023 01:38 PM No CBI No PII Photographer: Jon Jones Underground Maintenance at the 900 Main [Geographic Coordinates] View of used oil drain pads that are not labeled with the words "Used Oil." 32 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1675.jpg 09/11/2023 01:40 PM No CBI No PII Photographer: Jon Jones Underground Maintenance at the 900 Main [Geographic Coordinates] View of container, holding a waste lead-acid battery jump pack, seen here not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." [Title] IMG_1676.jpg 09/11/2023 01:40 PM No CBI No PII Photographer: Jon Jones Underground Maintenance at the 900 Main [Geographic Coordinates] Another view of container, holding a waste lead-acid battery jump pack, seen here not labeled with either the phrase "Universal Waste - Batteries," "Waste Batteries," or "Used Batteries." 33 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 [Title] IMG_1677.jpg 09/11/2023 01:52 PM No CBI No PII Photographer: Jon Jones Underground Maintenance 940 Paste Plant [Geographic Coordinates] View of the SAA container, showing that the attached aerosol can popper cover is open, and the container is not closed. [Title] IMG_1678.jpg 09/11/2023 01:54 PM No CBI No PII Photographer: Jon Jones Underground Maintenance 940 Paste Plant [Geographic Coordinates] View of the SAA container, after Ms. Joos closed the cover on the attached can popper, closing the container. 34 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): 09/11/2023 - 09/11/2023 APPENDIX 2: DOCUMENT LOG Document Type Document Name Contains Contains Uploaded Date CBI PII By Received Communications Jump Pack Battery Drums Labels.pdf No No Jon Jones 11/17/2023 Communications Jump Pack Battery Disposal.pdf No No Jon Jones 11/17/2023 Other - Invoice for the sale of used crucibles and gold bar slag Gold Slag Material Sale.pdf No No Jon Jones 11/17/2023 Contingency Plan KGM Contingency Plan October 2023.pdf No No Jon Jones 11/17/2023 Contingency Plan Quick Response Guide Kensington Mine .pdf No No Jon Jones 11/17/2023 Communications Items Noted During Inspection Update.pdf No No Jon Jones 11/17/2023 Other Container labeling Li Ion Battery Drums Labels.pdf No No Jon Jones 11/17/2023 Records Review Storage Room Inspections Dates.pdf No No Jon Jones 11/17/2023 Personnel Training Bailey_Ryan_RCRA-DOT_Sep20.2023.pdf No No Jon Jones 11/17/2023 Personnel Training Foster_Kristal_RCRADOT_Ship_EnviroPro_Aug022023.pdf No No Jon Jones 11/17/2023 Personnel Training JOOS_C~1.PDF No No Jon Jones 11/17/2023 Personnel Training Lake_Landon_RCRA_Sep21.2023.pdf No No Jon Jones 11/17/2023 Personnel Training Lammers_Sierra_RCRADOT_Ship_EnviroPro_Jul252023.pdf No No Jon Jones 11/17/2023 Personnel Training Lare_Maureen_RCRADOT_Refresher_08_14_2023.pdf No No Jon Jones 11/17/2023 Personnel Training RCRA01~1.PDF No No Jon Jones 11/17/2023 Personnel Training Strow, P RCRA Refresher_12_24_22.pdf No No Jon Jones 11/17/2023 Personnel Training Wodkowsk John_RCRA Refresh 08_13_2023.pdf No No Jon Jones 11/17/2023 Other - Coeur Alaska Document Request Coeur Alaska Document Request.docx No No Jon Jones 11/20/2023 Other - EPA EPA Questionnaire Response Assay Lab FINAL.pdf No No Jon Jones 11/20/2023 Questionnaire 35 of 36 Coeur Alaska, Inc. - Kensington Gold Mine Inspection Date(s): Response Assay Lab FINAL Other - EPA EPA Questionnaire Response Water Treatment Plants No Questionnaire FINAL.pdf Response Water Treatment Plants FINAL 09/11/2023 - 09/11/2023 No Jon Jones 11/20/2023 36 of 36