Document jygyOjBDK5dbqzR60B6vGnvZR
REPORT OF COMPLIANCE SAMPLING INSPECTION (CSI)
AT Former Madison Mine 1050 County Road 263 Fredericktown, MO 63645
NPDES NO: MO-098752
October 19-20, 2022
BY U. S. ENVIRONMENTAL PROTECTION AGENCY
Region 7 Enforcement and Compliance Assurance Division (ECAD)
INTRODUCTION
I performed a Compliance Sampling Inspection (CSI) at the Former Madison Mine in Fredericktown, Missouri from October 19, 2022, through October 20, 2022. The inspection was authorized by Section 308(a) of the Federal Water Pollution Control Act, as amended. This narrative report presents the findings of the inspection.
PARTICIPANTS
Environmental Operations Inc. (EOI) Eric Page, Principal Email: eric@environmentalops.com Aaron Callahan, Project Manager
Missouri Department of Natural Resources Hannah Goetz, Environmental Specialist Crosley Welch, Environmental Specialist
U. S. Environmental Protection Agency (EPA) Joe Heafner, Life Scientist (913) 551-7091 Email: heafner.joseph@epa.gov
PROCEDURES
On October 18, 2022, I contacted Mr. Callahan via phone to inform him that I would be conducting an inspection at the Former Madison Mine starting on October 19, 2022. He stated that he would be available on October 19, 2022. I arrived at the Former Madison Mine facility at approximately 9:00 a.m. and met with Mr. Page and Mr. Callahan. I then introduced myself, presented my credentials, and explained the purpose and procedures of the inspection. These procedures included completing a comprehensive inspection which would include a facility walk-through with photos (attachment 1), a check of the self-monitoring records, and the collection of samples from Outfalls 001, 002, and an exit interview.
On October 19, 2022, and October 20, 2022, I collected grab samples of the effluent at the effluent structures of Outfalls 001 and 002. I collected the effluent using clean, pre-labeled containers for the analysis of Non-Filterable Solids (NFS), Total Metals, Chlorides, and Sulfates, and Total Phosphorus. I measured the pH and temperature using a field meter.
I placed the samples I collected on ice in an ice chest, sealed the container and hand delivered the samples to the EPA Region 7 Science and Technology Center (STC) for analysis on October 20, 2022. I followed Region 7's LSASD standard operating procedures in the collection, packaging, transportation, and handling of the samples. Field Sheets and Chain of Custody forms were electronically submitted each day following Region 7 procedures.
FACILITY DESCRIPTION
The Former Madison Mine facility is a former subsurface metals mine that ceased operations in the 1960's. The facility is currently owned by Missouri Mining Investments LLC of St. Louis, Missouri. The facility is operated by Missouri Cobalt LLC (MOCO). MOCO has contracted with Environmental Operations Inc. (EOI) for the day to day operations at the facility. The physical address of the facility is 1050 County Road 263, Fredericktown, MO 63645. The mailing address for Missouri Mining Investments LLC is 1530 South 2nd Street, St. Louis, MO 63104. The facility has two discharge outfalls. A description of the discharge for each outfall is listed below.
Outfall 001: Continuous dam toe/blanket drain dry weather discharge; intermittent stormwater runoff from D tailing piles, unvegetated areas, and areas adjacent to Tollar Branch; and land disturbance stormwater runoff. The design flow is 4.0 million gallons per day (MGD) however flow is dependent upon precipitation.
Outfall 002: Continuous groundwater seepage, and intermittent discharge from metallurgical (Met) pond; (stormwater runoff from A, B, C, and E tailings piles); areas adjacent to the tributary to Saline Creek; and discharge of land disturbance stormwater runoff.
MOCO operates a froth flotation plant for concentration of valuable metals from the surface tailings (currently from the west side of the Met Pond). Metals that are reclaimed from the excavated tailings include cobalt, nickel, and copper. The flotation plant was installed and
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began operations in 2019. The concentrate is stored in piles that are covered by tarps or in roofed areas to limit exposure to stormwater. The processing plant utilizes water from Tailings Pond B. Process wastewater is recycled from the tailings pond and the pond does not discharge.
MOCO is also currently constructing a hydrometallurgical (hydromet) operation for metals reclamation from the tailings concentrate. The location of the future hydromet plant is southeast of the current processing area. Transfer of concentrate from the concentrate storage building will be conducted via covered conveyor systems.
Site drainage is designed so that disturbed areas drain through one of the two permitted outfalls, Outfall 001 or 002. Each outfall is equipped with sedimentation basins sized to treat a local 2year, 24-hour storm. Currently the existing Met Pond, and Basin G located upstream of Outfall 002, and the D Tailings Lake Dam upstream of Outfall 001 are used for this purpose. As part of the ongoing Early Removal Action, the D Tailings Lake has been drained and capped. The Met Pond will be drained, sediment removed for processing and metals reclamation, and then filled and capped. A series of six sedimentation basins (designated as Basins A, B, D, E, G and F) are currently under construction or have been constructed throughout the site to provide sedimentation for all storm water runoff discharges to Outfalls 001 and 002. Currently stormwater from B, C and E tailings areas flows in a northerly direction then is diverted to around the "Met" Pond and Stormwater Basin G, meets up with effluent from the "groundwater seep" below Stormwater Basin G outfall before discharging through Outfall 002. Mr. Page stated that eventually the stormwater will be diverted back through Stormwater Basin G, before being discharged through Outfall 002.
There is currently a construction project that is occuring north of the metal processing buildings that is disturbed. Stormwater from this area flows to the north through a series of ditch checks and sediment traps before discharging into a wooded area north of the facility.
Stormwater from the disturbed areas surrounding the proposed mine water pond area and the north surface plant area flows north and east through a series of ditch checks and sediment traps before it will discharge into a ditch along Z Highway through a proposed new outfall that will be designated as Outfall 008.
In addition, drainage channels are currently being constructed to collect and channel runoff to the stormwater basins. All stormwater discharges from disturbed areas which leave the site will pass through the existing or new detention basins described above, and/or through other sediment control measure such as silt fences or check dams prior to leaving the site.
The WWTF's National Pollutant Discharge Elimination System (NPDES) Permit NE-098752 was issued on February 1, 2019 (attachment 3). The permit was modified on November 1, 2019 and expired on September 30, 2021. The MDNR has administratively extended the current permit until a new permit has been issued. The facility has applied for a new NPDES permit, a draft permit was public noticed and is currently under review.
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REGULATED HISTORY The facility is currently under a Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), Consent Order (CERCLA-07-2018-0296) and is undergoing an Early Removal Action under the oversight of USEPA Region 7. The MDNR last inspected the facility on March 28, 2022 (attachment 4). MDNR found the facility to be in non-compliance for the following reasons:
x Failure to comply with effluent limits for Outfalls 001 and 002. x The facility discharged water contaminants that violated the Missouri Water Quality
Standards. x The facility failed to update and implement a Stormwater Pollution Prevention Plan
(SWPPP) as required by the NPDES permit. MDNR issued a Letter of Warning for the above-mentioned violations and required that the facility take corrective action to resolve the continued non-compliance. FINDINGS AND OBSERVATIONS The following findings were noted during the plant and record review. These findings were discussed with Mr. Page during the exit meeting. Self-Monitoring Data Review: I obtained a spreadsheet of the NetDMR data for the Former Madison Mine from January 2019, through October 2022, and reviewed the data. During the inspection, I also obtained an electronic copy of the facility's Discharge Monitoring Reports for the years 2019 - 2022.
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Tables 1A - 1D below represents the effluent violations noted at Outfalls 001 and 002 during the review.
Table 1A: Effluent violations reported for Outfall 001 from January 2019 - April 2022
Copper (Cu) Limit (ug/L) Lead (Pb Limit (ug/L) Nickel (Ni)
Sep-20 16.2
13
Feb-21 7.2
5.6/15.3
7.9
2.2/6.5
Mar-21 16.1/18 5.6/15.3 21.3/28.1 2.2/6.5
Apr-21 8.4
5.6/15.3
8.1
2.2/6.5
May-21 19.4
5.6/15.3
19.8
2.2/6.5
235
Jun-21 17.9
5.6/15.3
20.9
2.2/6.5
Jul-21
5.6/15.3
4.1
2.2/6.5
54.8
Aug-21 7.2
5.6/15.3
4.1
2.2/6.5
96.7
Sep-21 31.2
5.6/15.3
29.8
2.2/6.5
115
Oct-21 8.1
5.6/15.3
3
2.2/6.5
132
Nov-21 27.1
5.6/15.3
41.9
2.2/6.5
Dec-21 13.5
5.6/15.3
10.5
2.2/6.5
Jan-22 6.5
5.6/15.3
6.7
2.2/6.5
Feb-22 7.9
5.6/15.3
7.2
2.2/6.5
Mar-22 13.6
5.6/15.3
13.6
2.2/6.5
Apr-22 9.4
5.6/15.3
9
2.2/6.5
May-22 21.55/37.6 5.6/15.3 32.75/57.4 2.2/6.5
Jun-22
5.6/15.3
52.9
Aug-22
5.6/15.3
63.6
Limits are daily limits followed by monthly averages.
Limit (ug/L)
49.9/80.9 49.9/80.9 49.9/80.9 49.9/80.9 49.9/80.9
49.9/80.9 49.9/80.9
Chlorides + Sulfates Limit (mg/L) Total Suspended Solids (TSS) 31
1437
1000
1306
1000
1609
1000
144
72.5/128
Limit (mg/L) 30/45
30/45 30/45
Table 1B: Effluent violations reported for Outfall 002 from January 2019 - December 2020
Cobalt (Co Limit (ug/L) Copper (Cu) Limit (ug/L) Nickel (Ni) Limit (ug/L) Cadmium (Cd)
Nov-19 1550 817/1103
2480 407/818
Jan-20 1420 817/1103
2310 407/818
Feb-20 1675/2020 817/1103 510.2/963 13/26 2625/3050 407/818
Mar-20 1520 817/1103 182 13/26 2480 407/818
Apr-20 1330 817/1103 24.1 13/26 2150 407/818
May-20 1580 817/1103 13.7 13/26 2570 407/818
Jun-20 1470 817/1103 14.2 13/26 2410 407/818
Jul-20 1460 817/1103
13/26 2340 407/818
Aug-20 1540 817/1103 29.6 13/26 2560 407/818
Sep-20 1380 817/1103 43.6 13/26 2160 407/818
Oct-20 1820 817/1103
13/26 2870 407/818
Nov-20 1710 817/1103
13/26 2950 407/818
Dec-20 1680 817/1103 14.7 13/26 2370 407/818
Limits are daily limits followed by monthly averages.
Limit (mg/L)
Lead (Pb)
Limit (mg/L) Zinc (Zn) Limit (mg/L) Total Suspended Solids (TSS) Limit (mg/L)
116.8 104
450
30/45
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Table 1C: Effluent violations reported for Outfall 002 from January 2021 - December 2021
Cobalt (Co Limit (ug/L) Copper (Cu) Limit (ug/L) Nickel (Ni) Limit (ug/L) Cadmium (Cd)
Jan-21 1550 817/1103
13/26 2400 407/818
Feb-21 1370 693/1103 12.6 5.6/15.3 2200 49.9/80.9 0.3
Mar-21 1900 693/1103 81.4 5.6/15.3 2920 49.9/80.9 0.8
Apr-21 1390 693/1103 13.1 5.6/15.3 2200 49.9/80.9 0.3
May-21 1230 693/1103 43.9 5.6/15.3 1530 49.9/80.9 0.6
Jun-21 997 693/1103 17.6 5.6/15.3 1530 49.9/80.9 0.3
Jul-21 1050 693/1103 8.2 5.6/15.3 1990 49.9/80.9 0.3
Aug-21
693/1103 11 5.6/15.3 1220 49.9/80.9
Sep-21 1380 693/1103 19 5.6/15.3 2210 49.9/80.9 0.4
Oct-21 1150 693/1103 18.4 5.6/15.3 2050 49.9/80.9 0.3
Nov-21 1610 693/1103 20.3 5.6/15.3 2390 49.9/80.9 0.3
Dec-21 1380 693/1103 12.3 5.6/15.3 2080 49.9/80.9 0.3
Limits are daily limits followed by monthly averages.
Limit (mg/L)
0.2/0.5 0.2/0.5 0.2/0.5 0.2/0.5 0.2/0.5 0.2/0.5 0.2/0.5 0.2/0.5 0.2/0.5 0.2/0.5 0.2/0.5
Lead (Pb)
2.3 5.1 3.4 9.2 4.5 2.4 3.7 9.4 12.6 5.7 3.7
Limit (mg/L) Zinc (Zn) Limit (mg/L) Total Suspended Solids (TSS) Limit (mg/L)
2.2/6.5
2.2/6.5
2.2/6.5
2.2/6.5
2.2/6.5
2.2/6.5
2.2/6.5
2.2/6.5
61
30/45
2.2/6.5
108
2.2/6.5
2.2/6.5
Table 1D: Effluent violations reported for Outfall 002 from August 2022 - December 2022
Cobalt(Co Limit(ug/L) Copper(Cu) Limit(ug/L) Nickel(Ni) Limit(ug/L) Cadmium (Cd) Limit(mg/L) Lead (Pb) Limit(mg/L) Zinc (Zn) Limit(mg/L) TotalSuspended Solids(TSS) Limit(mg/L)
Jan-22 953 693/1103 20.3 5.6/15.3 2440 49.9/80.9 0.3 0.2/0.5 7.5 2.2/6.5
Feb-22 1470 693/1103 22.4 5.6/15.3 2310 49.9/80.9 0.3 0.2/0.5 9.3 2.2/6.5
Mar-22 1160 693/1103 9 5.6/15.3 1960 49.9/80.9
0.2/0.5 3.7 2.2/6.5
Apr-22 1350 693/1103 10.1 5.6/15.3 2000 49.9/80.9 0.3 0.2/0.5 4.5 2.2/6.5
May-22 1090 693/1103 8.4 5.6/15.3 1680 49.9/80.9
0.2/0.5
2.2/6.5
Jun-22 1250 693/1103 6.6 5.6/15.3 1930 49.9/80.9 0.3 0.2/0.5 3.6 2.2/6.5
Jul-22 1270 693/1103
5.6/15.3 1970 49.9/80.9
0.2/0.5
2.2/6.5
Aug-22 1560 693/1103 6.4 5.6/15.3 2360 49.9/80.9 0.3 0.2/0.5 3.9 2.2/6.5
Limits are daily limits followed by monthly averages.
Based on the review of the DMRs submitted, the facility has violated the effluent limits set forth in the permit 19 out of 46 months reviewed for Outfall 001 and 33 out of 46 months for Outfall 002. Furthermore, the facility has violated effluent limits for Cobalt at Outfall 002 for the past 32 of 33 months. The facility also has not complied with the effluent limits for Nickel at Outfall 002 for the past 33 months. I did note that the violations were a combination of daily limits and monthly averages.
During the exit briefing, I provided to Mr. Page a Notice of Preliminary Findings (NOPF) that included the reported effluent violations for Outfalls 001 and 002 (attachment 5). Mr. Page provided a response to the NOPF on with the following explanation to the effluent violations, "Effluent violations have historically been an issue for the Madison Mine Site dating back to the early 1990s. MMI has been striving improve the water quality of the effluent since it acquired the property in March 2019. Activities to improve the water quality have included implementing an Early Removal Action (consolidating and capping environmentally impacted surface materials) under USEPA oversight, constructing six (6) stormwater detention bases around the
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capped areas and site, and renewing the current MDNR NPDES permit containing revised effluent limits reflective of site-specific data. Following completion of the Early Removal Action, the critical activity to improve water quality will be the commencement of mine dewatering. Mine dewatering will cease water flow from a seep located near Outfall 002, the primary source of water influencing water quality. The mine dewatering is currently awaiting MDNR issuance of an Anti-Degradation Permit." (attachment 5)
Sample Results
The analytical results from the inspection were received on November 8, 2022, from the Region 7 STC laboratory. This data was not discussed during the exit interview. The analytical results for NFS, Metals, Chlorides, and Sulfates, pH, and temperature of the samples I collected are presented in Tables 2A and 2B. See attachment 6 for the analytical data packet.
Table 2A: Analytical Results for Effluent Samples Collected During Inspection for Outfall 001
Parameter
NFS (mg/L) Arsenic (ug/L) Cadmium(ug/L) Cobalt (ug/L) Copper (ug/L)
Lead (ug/L) Nickel (ug/L) Zinc (ug/L) Chloride (lbs/day) Sulfate (mg/L) Chloride+Sulfate Temperature (C)1
pH1 Flow in MGD
(October 19) Sample # 2200380-1 10.1 ND ND 127 10.6 ND 80.1 3.53 3.88 866 869.88 7.1 7.17 NA
(October 20) Sample# 2200381-1 21.6 2.58 ND 146 9.50 13.3 94.1 7.42 3.88 849 852.88 3.7 7.07 NA
Concentration Permit Limits2
45/30 *
0.5/0.2 1103/693 15.3/5.6 6.5/2.2 80.9/49.9 130.2/87.0
* * 1000/1000 NA 6.5 - 9.0 NA
1 oC = degrees Celsius, pH is not to be averaged, pH and temperature was measured in the field. 2Permit limits are the Daily Maximum followed by the Monthly Average.
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Table 2B: Analytical Results for Effluent Samples Collected During Inspection for Outfall
002
Parameter
(October 19) Sample #
(October 20) Sample#
Concentration Permit Limits2
2200380-2
2200381-2
NFS (mg/L)
11.6
4.16
45/30
Arsenic (ug/L)
1.03
ND
*
Cadmium(ug/L)
ND
ND
0.5/0.2
Cobalt (ug/L)
1210
1230
1103/693
Copper (ug/L)
6.87
4.0
15.3/5.6
Lead (ug/L)
2.53
1.56
6.5/2.2
Nickel (ug/L)
1870
1900
80.9/49.9
Zinc (ug/L)
62.8
55.6
130.2/87.0
Chloride (lbs/day)
12.3
5.69
*
Sulfate (mg/L)
670
682
*
Chloride+Sulfate
682.3
687.69
1000/1000
Temperature (C)1
17.3
12.9
NA
pH1
7.42
7.27
6.5 - 9.0
Flow in MGD
NA
NA
NA
1 oC = degrees Celsius, pH is not to be averaged, pH and temperature was measured in the field. 2Permit limits are the Daily Maximum followed by the Monthly Average.
Based on the sampling data, the facility violated the daily effluent limits for Lead and Copper at Outfall 001 on October 20, 2022. The facility also violated the daily effluent limits for Cobalt and Nickel at Outfall 002 on October 19 and 20, 2022.
Laboratory
Fomer Madison Mine utilizes Teklab of Collinsville, Illinois for all of its regulatory analysis with the exception of Whole Effluent Toxicity (WET) Testing. Analysis for WET is conducted by Pace Analytical Laboratories in Salina, Kansas.
After the completion of the inspection, Mr. Page provided the Analytical Data Sheets provided by Teklab for the years 2019 - 2022. I reviewed the data sheets and compared them with the Discharge Monitoring Reports and noted that there was consistency between the data sheets and DMRs. I also reviewed the data sheets to ensure that all sample analysis performed conforms with the NPDES permit and Chapter 40 Part 136 of the Federal Code of Regulations (40 CFR Part 136). I noted that all sample analysis does conform with the requirements of the NPDES permit and 40 CFR Part 136 of the Federal Regulations except for pH. 40 CFR Part 136 Table II requires that pH analysis is conducted within 15 minutes of the sample being collected. The laboratory data sheets indicate that a lab pH is being conducted after the sample has been received by the laboratory. I confirmed by reviewing the DMRs that the facility was using the lab pH as the reported pH on the DMR. I also reviewed the chain of custody records provided by
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the facility and it was confirmed that a field pH was not conducted on the received samples. The laboratory did note on the chain of custody forms that all holding times were met when in fact the holding times for pH were not being met. After my review, I placed the laboratory data sheets within the ECAD electronic file system.
SWPPP
The NPDES Permit requires that the facility has a SWPPP. During the inspection, I did a general review of the SWPPP documents that were available. During the exit briefing, I issued an NOPF for an inadequate SWPPP (NOPF 2). After the completion of the inspection, Mr. Page provided a copy of the SWPPP (attachment 7). After receiving a copy of the SWPPP from Mr. Page, I did a more comprehensive review. The following deficiencies of the SWPPP were noted during my review.
x The SWPPP does not have an adequate site map that shows the location of permanent and temporary BMPs to control stormwater discharges from the facility.
x The NPDES permit requires that the SWPPP reflect the current conditions of the facility and must be updated to reflect any changes. The current SWPPP does not include all sections of the facility. The SWPPP does not include Stormwater Basin F, which receives stormwater from the production area before discharging through the Met pond and into Basin G.
x The SWPPP states that all stormwater will pass through stormwater basins before discharging through either Outfall 001 or 002. Stormwater from Tailings Area B, C, and E are currently diverted west and north around the Met pond and Basin G. Stormwater flows around these structures and directly discharges into the tributary of Saline Creek through Outfall 002 (photos 1 & 41-43).
x The SWPPP does not mention all areas of the facility including the areas east of the production areas identified as the Mine Water Pond area and the North Surface Mine area. Stormwater from these areas flows to the east and through a series of sediment traps and other BMPs before discharging through a proposed Outfall 008 into a ditch along Highway Z (photos 17-19).
x The SWPPP does not mention areas east of the current production area. Stormwater in this area flows north through a series of rock checks and sediment traps, then discharges into a wooded area north of the area (photos 20-22).
x The SWPPP requires that track out areas be at all entrances to the facility. I did not observe track out BMPs at the east entrance along Highway Z.
The SWPPP requires routine inspections of the stormwater structures. The SWPPP states that inspections will be conducted once every seven calendar days and within 48 hours after a rain
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event equal to or greater than the 2 year-24 hour rain events. During the inspection, I reviewed inspection records from 2020 through the present and Mr. Page provided copies of the quarterly inspection reports from January 2021 through the time of the inspection. I reviewed the records provided by Mr. Page and noted that there were no inspections for January - March 2021. Each inspection report from April 2021 - September 2022, identified that the BMPs throughout the facility were deficient, however the inspections did not make it clear if those deficiencies were corrected. The permit requires that all actions that were taken to fix deficient BMPs be noted on the inspection report and to include any photos taken to note the corrective actions taken place. The inspection reports reviewed did not contain any corrective action reports and or photographs to document that deficiencies were corrected as required by the SWPPP and permit. After my review, I placed the SWPPP inspection reports that were provided into the ECAD electronic file system.
The SWPPP also requires that the facility maintain records of all SWPPP trainings that the facility has performed. I reviewed the training records for the facility during the inspection and noted that they were complete in accordance with the SWPPP and the permit. After the completion of the inspection, Mr. Page provided copies of the SWPPP training roster that was conducted in 2021 and 2022. After my review, I placed the SWPPP training records that were provided into the ECAD electronic file system.
Operational Issues and Observations
During the facility tour, I observed all areas of the facility including the stormwater flow paths throughout the facility and the two outfalls (photos 1-48). I noted that many areas of the facility had BMPs that were not adequate to protect the receiving streams for protecting water quality. These observations include:
x Throughout the facility, areas were bare of vegetation (photos 7-11,14-19, 35-38, and 4143). According to Mr. Page, the facility has purchased a hydro seeder to seed the bare areas. He also stated that the type of hydroseed does not utilize mulch, but a tacky substance to hold the seed in place. An issue with this method is that it is not as protective as utilizing mulch to hold seed down. Not mulching these areas also allow for the transportation of sediment during precipitation events.
x Silt fencing and straw waddles are utilized as a primary BMPs in many areas of the facility (photos 7-8, 17-19, 31-32, and 37-39). Much of the silt fencing was in need of repair and the straw waddles need to be replaced. Silt fencing was utilized on slopes that had steep grades (photos 17-19, and 28). Silt fencing is practical in these areas if it is used properly, however, in many instances there was one strand of silt fence for the entire slope instead of utilizing multiple strands of fencing on the slopes to control runoff from the slopes.
x Rock check dams were also observed throughout the facility (photos 18-20, and 28). The rock check dams that were observed during the inspection do not appear to be constructed as stated in the SWPPP. The SWPPP states that rock check dams will be constructed with 2-3 inch rock (attachment 7 page 30 of 49). All of the check dams observed were made
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with rock that was much larger than the 2-3 inch rock as stated in the SWPPP.
During the exit briefing, I issued a NOPF for the inadequate land disturbance controls in place at the time of the inspection (NOPF 3).
As stated above, I observed both outfalls during the inspection. Outfall 001 discharges intermittent stormwater runoff from D tailing piles, unvegetated areas, and areas adjacent to Tollar Branch along with land disturbance stormwater runoff from these areas. According to Mr. Page, groundwater seeping from the toe of the old tailings pond allows water to discharge on a continuous basis. During the inspection, there was little measurable flow discharging through the outfall (photos 12-13).
Outfall 002 receives continuous groundwater seepage, and intermittent discharge from the metallurgical (Met) pond; (stormwater runoff from A, B, C, and E tailings piles), areas adjacent to the tributary to Saline Creek, and discharge of land disturbance stormwater runoff. During the inspection, I noted that the continuous ground water seep contributes the majority of the flow through Outfall 002 (photos 3 and 34). I also noted that the seepage is not treated before being discharged through the outfall. Mr. Page stated during the inspection that the facility believes that once a new NPDES permit is issued that allows the facility to de-water the existing subsurface mine, this will cause the groundwater seep to stop discharging and violations of the NPDES permit will be eliminated.
Summary
The facility has had continuous effluent violations of the NPDES permit for both Outfalls 001 and 002.
The facility has an inadequate SWPPP that needs to include a site map and is updated to reflect the current conditions of the facility.
BMPs utilized by the facility are inadequate in providing protection from stormwater runoff from the facility.
JOSEPH
Digitally signed by JOSEPH HEAFNER
Date: 2022.11.29
_H_E_A__F_N__E_R____0_6:_10_:3_1 _-06_'0_0'__
Joe Heafner
Life Scientist
NICOLE
Digitally signed by NICOLE MORAN
Date: 2022.12.01
_M_O__R_A__N______0_8:_10_:5_6 -_06_'0_0'
Nicole Moran
Section Chief
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Attachments: 1. Digital Photographs with Photo Log (28 pages) 2. Facility Satellite Photos/Maps (3 pages) 3. NPDES permit issued on November 1, 2019 (15 pages) 4. MDNR Inspection Report from April 22, 2022 (24 pages) 5. Notice of Preliminary Findings and Facility Response (5 pages) 6. Laboratory Analytical Report for Activity JAH2301 (19 pages) 7. SWPPP (49 pages)
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