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SECTION .E: h10NITORINC AND COI~ANCE <br /> <br />12. Are the facility conditions properly reflected by the permit?N <br />if no, identify the differences: <br />At this time this facility is not required to have <br />an NPDES permit, however there is concern that the <br />containment pond liners may be leaking. According <br />to MLRD, they are not in compliance with their <br />lining permit, because of high levels of CN- in <br />tl~e ponds. <br />Is there a need for extra permit conditions? Y <br />If the containment ponds are leaking a permit will <br />be required. <br />13. Describe the physical condition of each discharge point. Is it <br />discharging? If so, at what flow? <br />At this time there is no surface discharge. <br />Concern is over possible CN- detected in a <br />processed sample from groundwater monitoring well <br />M-9. At this time BMG suspects that the CN- is <br />from the sampling and/or lab equipment. Further <br />analyses showed no CN- in this well. BMG is <br />applying For s TR for a new monitoring plan. This <br />plan will include sampling protocol (who, what, <br />when, where, and how) for the ponds and monitoring <br />wells. It may also include new wells. Proper <br />sampling QA should be investigated. <br />0.00000 <br />14. is the permittee maintaining records as required in the permit? Y <br />15. Are there any impoundments, land application, or ground water <br />monitoring wells present? Is there potential ground water impact? Y <br />If ao, please explain in detail. <br />As discussed previously, there is concern that the <br />containment ponds leak. Only one monitoring well <br />contains water, the other wells are dry for an <br />unknown reason. Construction methods of these <br />wells should be looked at to determine if they <br />were placed properly to intercept the intended <br />aquifers. <br />16. Flow measurement present? Y <br />If so, please describe the device and outfall. <br />Flow measurement is in the process control system <br />of the milling facility using in-line electronic <br />flow measurement devices. <br />17. Is the effluent in compliance with the permit? N <br />18. Is there a compliance schedule? Y <br />Is the entity meeting the compliance schedule? <br />