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3.0 Groundwater Protection Procedures <br />Groundwater & Surface -Water Monitoring Response Plan <br />Groundwater protection procedures will be implemented during operations and post- operations <br />when, based on confirmation samples, water - chemistry results indicate potential retort- derived <br />contamination within the monitored interval. Specific procedures will be developed to ensure <br />protection of groundwater resources based on immediate assessment of the reported <br />concentrations. Analytical results summaries, description of the data assessment process, data <br />assessment results, and the proposed groundwater protection procedures will be included in a <br />submittal to DRMS, BLM, and EPA. The proposed groundwater protection procedures will <br />include the steps or measures to be taken to ensure protection of groundwater resources and, if <br />necessary, a corrective action plan to reduce or otherwise mitigate the threats posed by the <br />contamination. <br />Once groundwater protection procedures are triggered, the monitoring frequency for the suspect <br />analytes, at a minimum, will be increased to monthly and existing data will immediately be <br />reviewed and evaluated to assess the threat(s) posed by the potential contamination and the <br />actions required to reduce or otherwise mitigate the threats. The assessment will consider the <br />analytes indicating potential retort- derived contamination, analyte concentration(s) relative to <br />baseline, and Colorado water - quality standards for groundwater and surface water. Groundwater <br />data will be evaluated with respect to standards established by CDPHE Water Quality Control <br />Commission (WQCC) for agricultural use, domestic use, and organic chemicals as set forth at 5 <br />CCR 1002 -41 (Regulation 41). Surface -water results for Black Sulphur Creek will be evaluated <br />with respect to stream standards for Segment 20 of the White River Basin, described as the <br />mainstems of Black Sulphur Creek including all tributaries and wetlands from the source to the <br />confluence with Piceance Creek. The use classifications established for Segment 20 include <br />Aquatic Life Cold 1, Recreation N, and Agriculture. <br />Comparison of baseline results to groundwater standards is presented in Table 1. As shown, <br />baseline results for several analytes in one or more samples exceed the groundwater standards for <br />domestic use, including chloride, sulfate, total recoverable phenolics, gross alpha, barium, <br />manganese, and molybdenum. Fluoride and iron concentrations in one or more samples exceed <br />the standards for both agriculture and domestic use, and boron concentrations in one or more <br />samples exceed the agriculture standards. One or more samples collected at MWP2 -WS <br />5 <br />