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2022-08-15_ENFORCEMENT - M1977410
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2022-08-15_ENFORCEMENT - M1977410
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Last modified
8/18/2022 7:51:56 AM
Creation date
8/17/2022 10:46:03 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977410
IBM Index Class Name
Enforcement
Doc Date
8/15/2022
Doc Name
Petition to Repeal MLRB Finding
From
Robert Botts Jr. Stinson LLLP
To
DRMS
Email Name
JPL
JLE
CMM
GRM
Media Type
D
Archive
No
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BLACK <br /> FOX <br /> MINING <br /> L L C <br /> 220425023-01 4/22/22 15:00 Silver ND ug/L PD <br /> 220425023-01 4/22/22 15:00 Zinc 3 ug/L PD <br /> 220425023-01 4/22/22 15:00 Copper 1.8 ug/L TR <br /> 220425023-01 4/22/22 15:00 Lead 3.2 ug/L TR <br /> Completed/Future Improvements <br /> GIR has taken proactive steps to ensure that each and every personnel has been retrained on the Standard <br /> Operating Procedures(SOPS)on operation of the WTP,sampling and continue daily meetings with all <br /> members of the GIR team to achieve results to a non-detect level and well below the permit requirements.1- <br /> micron bags have been introduced instead of the 5-mircon bags to provide a finer level of suspended particle <br /> removal prior to the MetSorb vessels.Two MetSorb vessels now run in series to guarantee a higher level of <br /> polishing and metal removal.New plumping is being installed in the coming weeks are the discharge location <br /> with an updated sample port so improved and efficient sample collection.Increased automation will be <br /> installed to track and trend data on the pressure drop across the MetSorb vessels to provide real-time data of <br /> when a vessel needs to be exchanged.In addition,each compliance sample will be taken with duplicate <br /> laboratory samples to be able to verify if a laboratory mistake has been made. <br /> Conclusion <br /> GIR has analyzed every potential reason for the outlying data.There was no change in operations of the WTP <br /> that could have resulted in the outlying data.During the month of February and March 2022,GIR was <br /> conducting numerous source water samples on the Cross and Caribou.This includes taking samples back in <br /> each portal of the perspective mines where mine activity produces higher metal concentrations.These <br /> samples utilized a 500 mL,unpreserved sample bottle to grab raw water and transfer to the sample bottles <br /> needed to run potentially dissolved and total recoverable analysis.At the discharge location of Outfall-001,a <br /> 500 mL bottle is used as well.The means of collecting the samples for discharge requirement access a capped <br /> section of 8"PVC pipe located in the discharge shed.This piping drops into a section where the discharge <br /> flowmeter is located.A 500 mL,unpreserved bottle is used to collect the samples and transfer them into the <br /> sample bottle set for compliance.Previously,this bottle was located in the Cross office.Even the similar <br /> methods of sample collection for both the raw source water and the discharge compliance,GIR believes <br /> human error caused these bottles to be misused and thus,causing cross contamination. <br /> As mentioned in the above section of completed/future improvements,a new sample port is to be installed in <br /> the coming week to eliminate the chance of cross contamination in the future.All staff have been retrained in <br /> the sampling procedures and sampling plan across the site. <br /> PAGE 28 of 29 <br />
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