MEMORANDUM

TO:	Tom Born, Ore Mining Task Lead, EPA

FROM:	Chris Krejci, ERG

DATE:	August 21, 2009

SUBJECT:	Summary of Available Discharge Data for the Ore Mining Category
(Rev1)



		ERG downloaded data from the Permit Compliance System (PCS) through
Envirofacts (available online at
http://www.epa.gov/enviro/html/pcs/adhoc.html) to compare the number of
permitted discharges from ore mining operations to the number of permits
with associated discharge data. These data are included in the attached
spreadsheet (List of NPDES Permits for Ore Mining Operations.xls).
ERG’s analysis of these data consisted of the following steps:

ERG grouped NPDES IDs by Federal Registry System (FRS) ID to identify
cases where multiple NPDES IDs are associated with one facility. ERG
checked the grouping of these permit IDs using the master facility list
for the Ore Mining Category that ERG is currently developing with EPA
(see DCN 06924). ERG did not identify any discrepancies.

ERG reviewed NPDES IDs to determine whether they were associated with
individual or general permits. ERG made this determination based on
whether the third character of the NPDES ID was a letter, indicating the
permit is a general permit, or a number, indicating the permit is an
individual permit.

ERG attempted to identify the type of general permit based on the NPDES
ID. ERG made this determination based on the form of the general permit
ID. In most cases, the first 5 or 6 letters of the general permit ID are
the first 5 or 6 letters of the facility’s individual NPDES IDs if
they have a general permit. For example, all facilities with the Alaska
General Permit AKG370000 (General Permit for Mechanical Placer Mining
Operations) will have NPDES IDs beginning with AKG370000 (e.g.,
AKG3700005). ERG excluded general permits for mechanical placer and
suction dredge mining from further analysis.

ERG identified those facilities for which discharge data are available
through Envirofacts.

  REF _Ref237658970 \h  \* MERGEFORMAT  Table 1  presents the number of
minor and major NPDES IDs by state for those states with significant ore
mining activity.

Table   SEQ Table \* ARABIC  1 . Summary of Permitted Discharges Covered
by the Ore Mining Point Source Category1



State2	Facility Counts	Type of Permit	Available Discharge Data

	# of Major NPDES IDs 	# of Minor NPDES IDs 	Total # of Facilities3	# of
Individual Permits	# of General Stormwater Permits4	# of Minor Permit
IDs with Discharge Data	# of General Permit IDs with Discharge Data5	%
of Minors with Discharge Data6

AK	5	35	40	15	25	1	0	3%

AZ	6	36	32	11	31	2	0	6%

CO	9	23	29	22	10	18	5	78%

MT	2	24	22	11	15	22	14	92%

ID	5	22	21	14	13	4	0	18%

CA	1	19	19	9	11	0	0	0%

MN	2	18	17	20	0	13	0	72%

WY	2	16	16	6	12	4	0	25%

NV	1	14	13	5	10	0	0	0%

TN	9	2	10	11	0	2	0	100%

UT	2	5	7	4	3	2	0	40%

MO	7	0	6	7	0	0	0	NA

NM	5	1	6	6	0	1	0	100%

SD	4	3	6	6	1	2	1	67%

FL	3	2	5	5	0	2	0	100%

SC	0	5	5	2	3	2	0	40%

WA	1	5	5	3	3	1	0	20%

MI	2	2	4	4	0	2	0	100%

AR	1	3	3	2	2	1	0	33%

PA	0	3	3	0	3	0	0	0%

VA	0	3	3	3	0	0	0	0%

AL	0	2	2	1	1	2	1	100%

NC	0	2	2	0	2	0	0	0%

NJ	0	2	2	2	0	1	0	50%

NY	2	0	2	2	0	0	0	NA

OR	0	2	2	2	0	1	0	50%

WV	0	2	2	0	2	0	0	0%

GA	0	1	1	1	0	1	0	100%

IL	0	1	1	1	0	1	0	100%

LA	0	1	1	1	0	0	0	0%

ND	0	1	1	1	0	0	0	0%

NE	0	1	1	1	0	1	0	100%

Total	69	256	289	178	147	86	21	46%

1 Excludes Mechanical Placer Mining and Suction Dredge Mining.

2 Listed in descending order of total number of facilities.

3 Includes minor and major NPDES IDs.

4 Includes multi-sector general stormwater permits, general stormwater
permits for mining and oil and gas only, and general construction
stormwater permits.

5 Included in the column titled “# of Minor Permit IDs with Discharge
Data.”

6 Includes general stormwater permits and industrial permits.

Based on this analysis, the following states have at least ten permitted
discharges regulated by general stormwater permits:

Arizona (31);

Alaska (25);

Montana (15);

Wyoming (12);

Idaho (13);

California (11);

Colorado (10); and

Nevada (10).

		States with the most data for minor NPDES facilities are Colorado (18
of 23 permits), Montana (22 of 24 permits), and Minnesota (13 of 18
permits); however, many states with only a few minor facilities provide
discharge data for all minor facilities (e.g., Tennessee, New Mexico).
In addition, Alabama, Colorado, Montana, and South Dakota each have
discharge data for at least one discharging operation permitted under a
general stormwater permit.

 The PCS queries available through Envirofacts also recover data from
the ICIS-NPDES data system.

 Permit types included the following:

Construction stormwater;

General stormwater;

General stormwater from mining and oil and gas activities;

Industrial stormwater;

Mechanical placer mining; and

Suction dredge mining.

Memorandum

August 21, 2009

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Memorandum

August 21, 2009

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