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construction of the facility beginning in 1977. The ground water monitoring <br />plan currently in operation at the loadout was initiated in 1987 (after coal <br />shipments had ceased at the loadout) and consists of the following (4.05.13(1)): <br />Two alluvial wells are monitored in the spring and fall to sample high <br />(snowmelt) and low water (base flow) conditions. Well HGDALl, which was <br />designed to sample alluvial conditions upgradient of the loadout, is located <br />in the alluvium of Stoker Gulch. Well HGDAL2, which was designed to <br />sample alluvial conditions downgradient of the loadout, is located in the <br />alluvium of Dry Creek. The list of parameters sampled is found in Table 13-2 <br />of Tab 13. <br />The current monitoring program has the following deficiencies: <br />A. Well HGDALl is not upgradient of all disturbance associated with the <br />loadout and well HGDAL2 is not downgradient of all disturbance associated <br />with the loadout. <~~~ <br />B. In addition, HGDALl is in Steksr Gulch alluvium-colluvium while <br />HGDAL2 is associated with Dry Creek alluvium; which has resulted in widely <br />different water quality data. Figure 3 displays monitoring to date for total <br />dissolved solids (TDS) for both wells. <br />C. Both wells sample the underlying Lewis shale in addition to sampling <br />alluvial\colluvial material. Although the Lewis shale is considered to be an <br />aquitard, waters in contact with the Lewis shale would conceivably be of <br />lower quality than that of the overlying alluvial material; which is of lower <br />quality than that of associated surface waters (refer to the Summary Section <br />(hydrologic balance) of this document). <br />In order to insure that results from the groundwater monitoring program are <br />representative of alluvial quality in the Dry Creek alluvium upstream and <br />downstream of the disturbance associated with the HG Loadout, a stipulation <br />has been added to the permit (see Stipulation # 3, below). <br />Surface Water Monitoring Plan <br />2. The applicant has and will continue to conduct monitoring of surface water <br />in a manner approved by the Division. The current monitoring regime began <br />in 1985 one year before shipments ceased at the HG Loadout and was <br />submitted under Rule 2.05.6(3)(b)(iv) and consists of the following <br />(4.05.13(2)): <br />Two surface sites are monitored in the spring and fall to sample high <br />(snowmelt) and low water (base flow) conditions. Sites HGSDl and HGSD2 <br />were planned to sample conditions upstream and downstream of the loadout, <br />is <br />