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Dry Creek alluvium downstream from the Loadout's facilities (4.05.13(1)). <br />The list of parameters analyzed is found in Table 13 -2 of Tab 13. <br />Ground Water Points of Compliance <br />Rule 4.05.13 requires establishment of groundwater points of compliance if, in <br />the judgment of the Division, the operation has the potential to negatively impact <br />the quality of ground water for which quality standards have been established by <br />the 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 />native ground water in the Lewis shale which has high concentrations of dissolved <br />solids. <br />Surface Water Monitoring Plan <br />2. The applicant has conducted and will continue to conduct, monitoring of <br />surface water in a manner approved by the Division. The current monitoring <br />regime began in 1985 one year before shipments ceased at the HG Loadout, <br />was 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 (snowmelt) <br />and low water (base flow) conditions. Sites HGSD1 and HGSD2 were planned to <br />sample conditions upstream and downstream of the loadout, respectively, along <br />Dry Creek. The list of parameters sampled is found in Table 13 -1 of Tab 13. <br />Hayden Gulch Loadout 22 November 22, 2011 <br />