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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />This was a partial inspection of the Hayden Gulch Loadout conducted by Mike Boulay of <br />the DMG. John Weinman of Hydro-Environmental Solutions Inc. was present during the <br />entire inspection. Mr. Weinman is the local company representative for Hayden Gulch <br />Terminal, Inc. (HGTn. <br />Weather conditions were cool and cloudy. Ground conditions were wet and muddy due <br />to recent snowmelt. Some patches of snow still remain at the site. This loadout facility is <br />in temporary cessation and there was no activity at the site at the time of this inspection. <br />The facility previously operated from 1980 to 1987 and in the eazly portion of the 1990's. <br />As part of this inspection, the sedimentation ponds, site ditches, ground water monitoring <br />wells and surface water sampling locations were inspected. The site was generally well <br />maintained and no significant erosion problems were noted during this inspection. The <br />Truck Loop Pond (Outfa11001A) was retaining water at a level approximately 2 feet <br />below the dischazge pipe. This pond is equipped with a Waterman Gate for discharge. <br />The Rail Loop Pond (Outfall 002A) has a single open-channel spillway designed to carry <br />sustained flows. The water level in this pond was well below the spillway. Both ponds <br />were frozen at the surface. Site ditches were dry at the time of the inspection and <br />appeared stable. It was noted that the existing ground water monitoring wells have a <br />minimal cement seal or bentonite chips only as a surface seal. For future installations, a <br />more substantial surface seal is recommended to preclude surface water infiltration in the <br />immediate vicinity of the well casing. <br />One reason for this inspection was to discuss with Mr. WeinmanlHGTI the need for <br />additional ground water monitoring upgradient of the site. As part of the review for <br />Technical Revision No. 6 (TR-06), the Division requested that one additional upgradient <br />monitoring well be installed to quantify background water quality specific to the alluvial <br />aquifer upgradient of the Loadout, and to determine potential impacts to ground water <br />from operations at the Loadout. The Division recommends that the additional monitoring <br />well be completed such that the perforated casing interval is installed entirely in the <br />alluvial aquifer above the Lewis Shale in a manner similaz to existing well HGDAL3. <br />As stated in our January 18, 2005 adequacy review letter for TR-06, the Division has <br />concern with the current ground water monitoring program. HGTI currently monitors <br />ground water level and quality in one downgradient alluvial monitoring well (HGDAL3). <br />Ground water monitoring was previously conducted at two additional sites HGDALI <br />(upgradient) and HGDAL2 (downgradient) between 1987 and 1995. In 1993 HGTI <br />installed HGDAL3 as a result of DMG concerns that the HGDALI and HGDAL2 were <br />partially completed in the Lewis Shale. Ground water monitoring ceased for HGDALI <br />