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Information on Surface and Ground Water Monitoring is found in Volume 3, Tab <br /> 13 of the PAP. <br /> Ground Water Monitoring Plan <br /> 1. The applicant will conduct monitoring of ground water in a manner approved <br /> by the Division. Baseline data was collected in 1977 and 1978 with <br /> construction of the facility beginning in 1977. No ground water monitoring <br /> wells are associated with the TAHR. The ground water monitoring plan <br /> currently in operation at the loadout consists of taking samples in the spring <br /> and fall from wells HGDAL 3 and HGDAL 4. Well HGDAL 3 is completed <br /> in Dry Creek alluvium downstream from the Loadout facilities. HGDAL 4 is <br /> completed in shallow alluvium upstream of the Loadout adjacent to Dry <br /> Creek,below the confluence of Stokes Gulch and Dry Creek(4.05.3(1)). The <br /> list of parameters analyzed for both wells is found in Table 13-2 of Tab 13 of <br /> the PAP. <br /> Ground Water Points of Compliance <br /> Rule 4.05.13 requires establishment of groundwater points of compliance if, in the <br /> judgment of the Division, the operation has the potential to negatively impact the <br /> quality of ground water for which quality standards have been established by the <br /> Water Quality Control Commission. Groundwater points of compliance are <br /> unwarranted at the Loadout, as discussed below. <br /> Alluvial Ground Water—Dry Creek alluvial ground water in the area down- <br /> gradient from the main surface disturbance of the Loadout can be classified as <br /> "Limited Use and Quality" based on natural TDS concentration being consistently <br /> above 10,000 mg/1 in alluvial ground water well HGDAL-3. Ground water <br /> classified as"Limited Use and Quality" has limitations for only radioactive or <br /> organic pollutants. The Loadout is not likely to generate significant amounts of <br /> radioactive or organic pollutants; therefore, the operation does not have the <br /> potential to negatively impact the quality of ground water in the Dry Creek <br /> Alluvium. <br /> Bedrock Ground Water—The Loadout does not have the potential to negatively <br /> impact bedrock ground water quality due to the fact that any leachate originating <br /> from the Loadout would lack sufficient hydraulic head to significantly invade the <br /> bedrock unit underlying the area (low permeability Lewis shale). This marine <br /> shale confines aquifer units in the underlying Mesaverde Group (Scott and Kaiser, <br /> 1994, Hydrologic Survey Resources Series 30, page 63). Several hundred feet of <br /> 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 /> 19 <br />