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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 />and HGDAL2 in 1995. The existing monitoring program is the result of considerable <br />discussion between HGTI and DMG, and subsequent revision to the permit (Technical <br />Revision No. 1 and Permit Renewal No. 1). It is noted in the PAP that upgradient surface <br />water and ground water variability exists due to potential contaminant sources from <br />irrigation return flows, adjacent dryland farming drainage, and seeps or subsurface flow <br />from the Lewis Shale. HGTI indicates in the PAP that the variability cannot be totally <br />eliminated or quantified regardless of the location of upgradient monitors. HGTI further <br />states the alluvial aquifer has been and continues to be unsuitable for use as irrigation or <br />stock water. <br />The Division's concern is that this information has not been fully validated and there has <br />been no specific monitoring data provided for the alluvial aquifer upgradient of the <br />Hayden Gulch Loadout. <br />After conducting an inspection of the site and the existing ground water monitoring wells <br />and based on the discussions with Mr. Weinrnan, the Division recommends the following <br />course of action be taken in response to Item 18 of our TR-06 adequacy review letter. <br />Prior to installing an additional upgradient monitoring well at the Hayden Gulch Loadout, <br />HGTI will conduct a review of existing off=site wells that have previously been installed <br />upgradient of the Loadout. These wells aze not associated with the Loadout but may <br />provide useful information. The review of existing wells should include well depth and <br />construction information, lithologic information, available ground water chemistry, and <br />ground flow direction and gradient. If the existing well information can be utilized for <br />background water quality data for the alluvial aquifer, then an additional monitoring well <br />will not be required. <br />A tentative location was selected for an additional ground water monitoring well (if <br />deemed necessary) following the review of existing well information. The location for <br />the well is adjacent to Dry Creek below the confluence of Stokes Gulch and Dry Creek <br />(south of the permit boundary). Access for drilling will have to be secured before a final <br />location is selected. <br />Since wells HGDAL 1 and HGDAL 2 are not optimally located and are no longer utilized, <br />these wells should be abandoned and an abandonment report submitted to the Division in <br />accordance with Rule 4.07.3. The PAP should also be updated at this time if there will be <br />changes to the approved monitoring plan as a result of the TR-06 adequacy review. <br />