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No impoundments other than sediment structures are proposed. <br />G. Ground and Surface Water Monitoring <br />Information on Surface and Ground Water Monitoring is found in Volume 2, Tab 13 <br />of the permit application. Please refer to Figure 2 of this document for the locations <br />of all ground and surface water monitoring sites. <br />Ground Water Monitoring Plan <br />1. The applicant will conduct monitoring of ground water in a manner approved by <br />the Division. Baseline data was collected in 1977 and 1978 with construction of <br />the facility beginning in 1977. The ground water monitoring plan currently in <br />operation at the Loadout consists of taking samples in the spring and fall from <br />well HGDAL 3, which is completed in Dry Creek alluvium downstream from the <br />Loadout facilities, and well HGDAL 4, which is completed in Dry Creek alluvium <br />upstream of the Loadout (4.05.13(1)). The list of parameters analyzed is found in <br />Table 13-2 of Tab 13. <br />Groundwater Points of Compliance <br />Rule 4.05.13 requires establishment of ground water 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. Ground water points of compliance are <br />unwarranted at the Loadout, as explained below. <br />Alluvial Ground Water - Dry Creek alluvial ground water in the area downgradient <br />from the main surface disturbance of the Loadout (the "specified area") can be <br />classified as "Limited Use and Quality" based on the natural TDS concentration being <br />consistently above 10,000 mg/1 in alluvial ground water well HGDAL-3. Ground <br />water 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 potential <br />to negatively impact the quality of ground water in the Dry Creek alluvium. <br />Bedrock Ground Water - The Loadout does not have the potential to negatively <br />impact bedrock ground water quality because any leachate originating from the <br />Loadout would lack sufficient hydraulic head to significantly invade the bedrock unit <br />underlying the area (the low-permeability Lewis Shale). This marine shale confines <br />aquifer units in the underlying Mesaverde Group (Scott and Kaiser, 1994, Hydrologic <br />Setting of the Upper Mesaverde Group, Sand Wash Basin in Colorado Geological <br />Survey Resource Series 30, page 63). Several hundred feet of Lewis Shale separate <br />the Loadout from the deeper Mesaverde Group. As a loadout (rather than a mine), the <br />operation will have no deep excavations or deep impoundments where water could <br />develop significant hydraulic head. In addition, any leachate originating at the <br />17