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Well HGDAL3 is downgradient of the Loadout. It was drilled in 1993. It <br />displays a slightly decresing TDS trend; however, the peak TDS value <br />occurred in June 1997. <br />Well HGDAL4 is upgradient of the Loadout. It was drilled in 2005. It <br />displays an increasing TDS trend, with the peak TDS value occurring in <br />May 2014. <br />This year's ground water quality was compared against CDPHE ground water <br />agricultural use standards (CDPHE, Reg. 41, 2008) . Results of those <br />comparisons are presented in Table 4. <br />Both wells exceeded the manganese standard (0.2 mg /1) in both May and <br />September. It should be noted that, while the CDPHE uses a manganese <br />standard of 0.2 mg /l, the EPA states that this standard is used to <br />protect crops grown in soils with a pH value lower than 6.0. In January <br />2008, CDPHE revised their ground water agricultural standard to reflect <br />this pH qualifier. In soils with a higher pH (as are found in the HGT <br />region), a more appropriate standard would be 10 mg /l (EPA. 1976. <br />"Quality Criteria for Water "). This year, neither of the Loadout wells <br />displayed a manganese value higher than 3.620 mg /l. <br />Downgradient Well HGDAL3 exceed the boron standard, 750 ug /1, with a <br />value of 920 ug /l in September. According to the CDPHE, the 750 ug /l <br />standard is set for sensitive crops (CDOH, Reg. 41, 2008), and that the <br />limit otherwise is 5000 ug /1. None of these sensitive plant species are <br />grown commercially in this area. <br />In a letter dated June 5, 2008, Tom Kaldenbach of the CDRMS stated that <br />"Groundwater points of compliance are unwarranted at the Hayden Gulch <br />Loadout...". He further concluded that "... any leachate originating at the <br />loadout would likely be of better quality than native groundwater in the <br />Lewis Shale which has high concentrations of dissolved solids." This <br />letter was provided in the 2008 AHR, Figure 3 (Appendix A). Monitoring <br />conducted this year at the Loadout supports these conclusions. <br />5 <br />