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Lewis shale separate the Loadout from the deeper Mesaverde Group. As a <br />loadout (rather than a mine), the operation will have no deep excavations or deep <br />impoundments where water could develop significant hydraulic head. In addition, <br />any leachate originating at the Loadout would likely be of better quality than <br />native ground water in the Lewis shale which has high concentrations of dissolved <br />solids. <br />Surface Water Monitoring Plan <br />2. The applicant has conducted, and will continue to conduct, monitoring of <br />surface water in a manner approved by the Division. The current monitoring <br />regime began in 1985 one year before shipments ceased at the HG Loadout, <br />was submitted under Rule 2.05.6(3)(b)(iv) and consists of the following <br />(4.05.13(2)): <br />Two surface sites are monitored in the spring and fall to sample high (snowmelt) <br />and low water (base flow) conditions. Sites HGSD 1 and HGSD3 were planned to <br />sample conditions upstream and downstream of the loadout, respectively, along <br />Dry Creek. The list of parameters sampled is found in Table 13 -1 of Tab 13. <br />In addition to the monitoring discussed above, the operator is required to monitor <br />discharges from two NPDES discharge points (sediment ponds) as required by the <br />mine's NPDES permit. <br />H. Transfer of Wells <br />No transfer of wells is proposed. Monitoring wells HGDAL3, HGDAL4, and the <br />Yampa Valley Alluvial Well will be reclaimed prior to final bond release <br />(4.05.14). <br />I. Discharge of Water into an Underground Mine <br />No surface water will be discharged into underground mine workings (4.05.15). <br />J. Stream Buffer Zones <br />The PAP for HGLO discusses buffer zones on pages 3 - 4 in Tab 14, but references <br />the old version of Rule 4.05.18. The rule changed in March 2001, and the PAP <br />will need to be updated to reflect the change in the rule (The old language of the <br />rule requires buffer zones for perennial streams or streams with a biological <br />community; in the revised language the rule applies to perennial, intermittent, or <br />ephemeral streams with drainage area greater than one square mile). <br />The PAP calls for buffer zones for Dry Creek and Sage Creek. The PAP does not <br />discuss the need (or lack of need) for buffer zones along other creeks, such as <br />Stokes Gulch and Grassy Creek. It is unclear if these other creeks are large <br />enough to warrant having buffer zones. At some point in the near future, a buffer <br />Hayden Gulch 24 February 11, 2014 <br />