2018-02-05_REVISION - C1992081 (29)

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No impoundments, with the exception of the two sediment ponds, are approved or proposed. G. Surface and Groundwater Monitoring Information on Surface and Ground Water Monitoring is found in Volume 3, Tab 13 of the PAP. Ground Water Monitoring Plan 1. The applicant will conduct monitoring of ground water in a manner approved by the Division. Baseline data was collected in 1977 and 1978 with construction of the facility beginning in 1977. No ground water monitoring wells are associated with the TAHR addition to the permit. The ground water monitoring plan currently in operation at the loadout consists of taking samples annually from wells HGDAL 3 and HGDAL 4. Well HGDAL 3 is completed in Dry Creek alluvium downstream from the Loadout facilities. HGDAL 4 is completed in shallow alluvium upstream of the Loadout adjacent to Dry Creek, below the confluence of Stokes Gulch and Dry Creek (4.05.13(1)). The list of parameters analyzed for both wells is found in Table 13-2 of Tab 13 of the PAP. Ground Water Points of Compliance Rule 4.05.13 requires establishment of groundwater points of compliance if, in the judgment of the Division, the operation has the potential to negatively impact the quality of ground water for which quality standards have been established by the Water Quality Control Commission. Groundwater points of compliance are unwarranted at the Loadout, as discussed below. Alluvial Ground Water — Dry Creek alluvial ground water in the area down - gradient from the main surface disturbance of the Loadout can be classified as "Limited Use and Quality" based on natural TDS concentration being consistently above 10,000 mg/1 in alluvial ground water well HGDAL-3. Ground water classified as "Limited Use and Quality" has limitations for only radioactive or organic pollutants. The Loadout is not likely to generate significant amounts of radioactive or organic pollutants; therefore, the operation does not have the potential to negatively impact the quality of ground water in the Dry Creek Alluvium. Bedrock Ground Water — The Loadout does not have the potential to negatively impact bedrock ground water quality due to the fact that any leachate originating from the Loadout would lack sufficient hydraulic head to significantly invade the bedrock unit underlying the area (low permeability Lewis shale). This marine shale confines aquifer units in the underlying Mesaverde Group (Scott and Kaiser, 1994, Hydrologic Survey Resources Series 30, page 63). Several hundred feet of 911