2014-07-02_INSPECTION - C1996083

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clarification as to how the language in their NPDES permit should be interpreted. As a result of this meeting, it is my understanding that the operator is only required to perform a grab sample in the event that they observe sheen during discharge. While this seems counterintuitive, it has been determined that the operator is in compliance with the rules of their NPDES permit. However, by taking no notice of job site BMP's (i.e. no secondary containment beneath generator pumps, 1 qt oil bottles floating, and no proactive measures to sample for oil /grease), BRL runs the risk of potential violations in the event of any future discharge. OSMRE strongly encourages that BRL reassess their day -to -day "housekeeping" protocol. Pond J and associated drainages The Drainage leading to Pond J also has excessive sediment /refuse deposition and is preventing positive flow. Maintenance is needed. Pond J was holding water but was not discharging at the time of inspection. This pond has been designed to discharge by using a generator pump as needed. There are two inflows and an emergency spillway that was functioning as designed. Pond D Pond D receives water from Pond J and Pond C. Pond D was holding water at the time of inspection. Overall, this pond was stable and no rills /gullies were observed. Pond K and associated drainages Pond K collects runoff from the batch weigh loadout and surrounding area. This pond was dry at the time of inspection. There is a pipe that discharges into the Pond K drainage area that is not in the approved plans. Just below where this pipe was located, there is a 24" corrugated culvert that receives runoff from the load out and is designed to drain to Pond K. Several hay waddles, tumble weeds and approximately 18" of refuse deposition are clogging the culvert. Maintenance is needed. There are two inflows to this pond that appeared to be functioning as designed. Map 22- K/engineer certification (Pond K Detail) indicates that the pond will be dewatered by pumping when necessary. No pump was present. Three trees (6 -8' tall) have established in the pond. The silt fence that mirrors the permit boundary of Pond K is non - functional. Maintenance is needed. General Compliance: Although no compliance issues or disturbances outside the permit area were noted, a better attention to detail regarding cleanliness, preventative maintenance and the use of BMP's are recommended. Maintenance items identified during inspection: • Weed spraying • Drainage and culvert maintenance /repair • Silt fence repair /maintenance • Drainage pipe near Gob #3 needs to be identified, included in the permit and designed appropriately • Removal of trees growing in pond K