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NPDES Compliance Inspection Report Friday Exploration Project Elk City, Idaho NPDES Tracking Number: #IDR050265 Inspection Date: 8/31/2023 Prepared by: CJ Langlois U.S. Environmental Protection Agency, Region 10 Enforcement & Compliance Assurance Division Water Enforcement & Field Branch Field, Data & Drinking Water Enforcement Section Inspector Signature/Date: Langlois, Curmit Digitally signed by Langlois, Curmit Date: 2024.01.31 04:40:09 -08'00' Supervisor Signature/Date: PETER CONTRERAS Date: 2024.01.31 08:45:18 -08'00' Digitally signed by PETER CONTRERAS Friday Exploration Project #IDR050265 Contents I. II. III. IV. V. VI. VII. VIII. VII. IX. X. Facility Information ................................................................................... 3 Inspection Information ............................................................................. 3 Permit Information ................................................................................... 4 Enforcement Background........................................................................... 4 Inspection Chronology ............................................................................. 4 Opening Conference.....................................................................................................5 Laboratory Inspection...................................................................................................6 Site Review................................................................................................ 6 File Review................................................................................................ 7 Areas of Concern. ................................................................................................... 7 Closing Conference................................................................8 Attachment A - Aerial Image & Site Map Attachment B - Photograph Log 2 of 14 Friday Exploration Project #IDR050265 [Unless otherwise noted, all details in this inspection report were obtained from conversations with Ms. Robin Hunt and James Lloyd, a review of facility documents, and/or from observations made during the inspection.] I. Facility Information Facility Name: Friday Exploration Project Facility Owner/Operator: Endomines Physical Address: 6 Quartz Creek Rd. Elk City, ID, 83525 Mailing Address: P.O. Box 132 Elk City, ID, 83525 Lat/Long: 45.7037241 N, -115.5413193 W Facility Contacts: Robin Hunt, Site Administrator Friday Exploration Project Office: (208) 451-2521 Email: robin.hunt@endomines.com James Lloyd, Environmental Contractor (November, 2022 - Present) Lloyd Mining Services Cell (406) 465-7328 Email: lloydminingservices@gmail.com Permit Number: SIC Code: #IDR050265 1041 (Gold Ore Mining) Nearest Surface Water: Crooked River II. Inspection Information Inspection Date: August 31, 2023 3 of 14 Inspectors: Friday Exploration Project #IDR050265 CJ Langlois EPA Region 10, ECAD / WEFB / FDDWES Phone: 206-553-2739 Arrival Time: 1:45 p.m. Departure Time: 3:45 p.m. Weather: Partly Cloudy, 63 F Purpose: To evaluate compliance with the requirements of the Clean Water Act (CWA) and the National Pollutant Discharge Elimination System (NPDES) MultiSector General Permit, Sector G, for Stormwater Discharges Associated with Industrial Activity in Idaho. III. Permit Information The Friday Exploration Project is permitted under the EPA's MSGP (MultiSector General Permit), Sector G (Metal Mining - ore mining and dressing), and Subsector G2. The MSGP was issued on January 15, 2021. On July 1, 2021, the Idaho Department of Environmental Quality (DEQ) became the delegated authority for the permit. DEQ is now responsible for issuing permits and assuring compliance with the permits. IV. Enforcement Background The Friday Exploration Project has not had any enforcement actions in the past five years according to the Integrated Compliance Information System (ICIS). V. Inspection Chronology This was an unannounced inspection. On August 31, 2023, I arrived at the facility at 1:45 p.m. I met Ms. Hunt outside of the facility's office and stated the reason for my visit. We then walked into the facility's office where I explained the scope of my inspection. I presented my credentials to Ms. Hunt and provided my business card along with a Small Business Administration 4 of 14 Friday Exploration Project #IDR050265 (SBA) form to her. Ms. Hunt answered all my questions and I was not denied access to any area of the facility. The inspection at the site lasted until approximately 3:45 p.m. VI. Opening Conference I began the inspection with a brief opening conference in the facility's office and explained the scope of the inspection to Ms. Hunt. I handed over an SBA (Small Business Administration) form, a business card, and commenced a file review. Ms. Hunt is the Site Administrator and is in charge of the site inspections as required by the permit. Typical operating hours for the site are 5 a.m. - 3 p.m., Monday through Thursday. At the time of my inspection, there were four individuals employed at the site. In 2019, Endomines took over the operation. Endomines is the operator and owner of Friday Exploration Project and is based out of Finland. The Friday Exploration Project is located deep into the mountains of Idaho and approximately 10 miles southwest of Elk City, Idaho. The site covers approximately 6.1 acres of land. The nearest body of water is Crooked River which is located approximately 250 feet away from the site within a valley. At the time of my inspection, only dewatering operations were being conducted to keep the mine from filling in with water. The last date of processing, mining, and drilling was back in February of 2022. It is now in a care and maintenance schedule. On an averge day, 50,000 gallons of water are pumped out of the mine. This water is then pumped out to an LAD (land area dispersement) system. This system is comprised of pumps, pipes, and hoses that attempts to evenly spread out the wastewater onto the slopes of the mountain on which the Friday Exploration Project is located to allow for an infiltration application. In September of 2022, the area was affected by the Williams Creek Fire which burned many trees in the area along with part of the LAD system which has since been repaired. The main order of business at the site is to mine gold ore. Primary activities at the site consist of drilling, mining, and exploring gold ore. Red dye diesel, regular diesel, gasoline, lubricants, explosives, drilling fluids, and antifreeze are stored and used on-site. They have some potential to be exposed to stormwater. Vehicle maintenance is also conducted on-site but is done so in a designated shed. 5 of 14 Friday Exploration Project #IDR050265 VII. Laboratory Inspection Friday Exploration Project utilizes Energy Labs located in Helena, Montana. Samples are kept preserved with ice in a cooler and are transported by James Lloyd. The laboratory analyzes for arsenic, cadmium, copper, iron, lead, manganese, mercury, zinc, and for TSS (total suspended solids). Parameters analyzed in-house include pH, temperature, SC, ORP, and DO. Grab samples are collected from both outfalls 001 & 002. In June of 2019 and 2021, no monitoring data was submitted for any parameter (a total of 68 non-receipt violations in ICIS). It is unclear the reasoning behind this because a different environmental contractor was employed by Endomines at that time and that information was not passed down. VIII. Site Review Ms. Hunt took me on a tour of the facility. A site map and aerial image appear in Attachment A and a photograph log appears in Attachment B. The Friday Exploration Project is located on a mountain with moderate to heavy vehicle traffic. During the time of inspection, very limited traffic was observed due to its current "care and maintenance" schedule. There are several areas within the site that fall under the regulation of the permit and are mentioned throughout the SWPPP (Stormwater Pollution Prevention Plan). These areas include vehicle and equipment fueling areas, access roads, stockpiles of ore, LAD application areas and storages of various petroleumbased products (Photo 1). I observed petroleum storage areas with secondary containment. Nitrates are also stored on-site in an explosives storage area. During times of dry weather, water is sprayed on disturbed areas, as appropriate, to mitigate dust. The two designated outfalls for the site do not seem to be from a point source, but rather from runoff down the sides of the mountain on which the site is located. This runoff ultimately makes its way to the Crooked River but during the time of the inspection, no stormwater runoff was observed due to the dry conditions. The first designated outfall is 001 - Quartz Creek (Photo 2). Quart Creek joins the Crooked River at a confluence approximately 200 feet 6 of 14 Friday Exploration Project #IDR050265 from the site. The second designated outfall is 002 - Crooked River. During the inspection, Ms. Hunt and myself drove down to the Crooked River where she believed the majority of the runoff was occuring. The river was fairly turbid during the time of the inspection but there was no clear evidence that this was directly related to the Friday Exploration Project. This also could be attributed to the wildfire that ravaged the area (Photos 3 & 4) in 2022. I observed sediment fences, berms, ditches, and straw bales in place to help mitigate erosion of area sediments. Towards the bottom of the site, I did observe sediment fence that was damaged (Photo 5) and that would be ineffective during a rain event. IX. File Review I reviewed the following records: Routine Inspection Reports - 2022. Quarterly Visual Assessments - 2022 Stormwater Pollution Prevention Plan (SWPPP) - December 2019 Analytical Lab Report - August 2023 Sampling Field Notes - July 2023 X. Areas of Concern 1) Electronic Reporting Requirement Section 7.2 of the permit states that "You must submit all NOIs, NOTs, NECs, Annual Reports, Discharge Monitoring Reports (DMRs), and other reporting information as appropriate electronically, unless the EPA Regional Office grants you a waiver based on one of the following conditions: If your headquarters is physically located in a geographic area (i.e., zip code or census tract) that is identified as under-served for broadband Internet access in the most recent report from the Federal Communications Commission; or If you have limitations regarding available computer access or computer capability. Waivers are only granted for a one-time use for a single 7 of 14 Friday Exploration Project #IDR050265 information submittal, e.g., an initial waiver for an NOI does not apply for the entire term of the permit for other forms. If you need to submit information on paper after your first waiver, you must apply for a new waiver. The EPA Regional Office may extend a wavier on a case-bycase basis. If you wish to obtain a waiver from submitting a report electronically, you must submit a request to the applicable EPA Regional Office, found in Part 7.8. In that request you must document which exemption you meet, provide evidence supporting any claims, and a copy of your completed paper form. A waiver may only be considered granted once you receive written confirmation from EPA or its authorized representative." In June of 2019 and 2021, no monitoring data was submitted for any parameter (a total of 68 non-receipt violations in ICIS). Section 7.2 of the permit requires that all DMRs be submitted. Section 7.3.4 requires that all monitoring data be submitted "no later than 30 days after receiving your complete laboratory results for all monitored discharge points for each monitoring period...." 2) Annual Report Section 7.4 of the permit states that "You must submit an Annual Report to EPA via NeT-MSGP, per Part 7.2, by January 30th for each year of permit coverage containing information generated from the past calendar year...." The Annual Reports for 2022 and 2023 were not submitted on time. The Annual Reports must be submitted by January 30th, for the previous year, as stated in the permit. 2) Closing Conference A closing conference was held with Ms. Hunt on the afternoon of August 31, 2023. I stated that no obvious areas of concern were identified over the course of the inspection and gave a brief overview of the post-inspection process. I thanked her for her time and assistance. 8 of 14 Attachment A Site Map & Aerial Image Friday Exploration Project #IDR050265 Figure 1 - Aerial image taken from Google Maps 9 of 14 Friday Exploration Project #IDR050265 Figure 2 - Site map provided by Friday Exploration Project 10 of 14 Friday Exploration Project #IDR050265 Attachment B Photo Log (Photographs were taken by CJ Langlois on August 31, 2023, with an Olympus Touch TG-6.) Photo 1 - Fuel storage and secondary containment 11 of 14 Friday Exploration Project #IDR050265 Photo 2 - Quart Creek - Outfall 001 12 of 14 Friday Exploration Project #IDR050265 Photo 3 - Wildfire damage Photo 4 - Wildfire damage 13 of 14 Friday Exploration Project #IDR050265 Photo 5 - Damaged and down sediment fence 14 of 14