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RESULTS AND DISCUSSION <br />Results of the September 26, 2012 groundwater sampling are provided in Table 1. <br />Historical results for the compliance suite for all wells are shown in Table 2. Table 2 also <br />presents the average and standard deviation statistics for compliance suite constituents, <br />based on the monitoring history for each well. Figure 2 presents time versus concentration <br />plot for TDS. Analytical results provided by the contract laboratories are presented in <br />Appendix A. <br />General Chemistry (TDS) <br />General chemistry parameters do not have primary health based standards. TDS has a <br />secondary drinking water standard of 500 mg/L and a Colorado State Numeric Protection <br />Level (NPL) of 2,630 mg/L. As shown in Table 2, TDS in concentrations have exceeded <br />the 500 mg/L secondary domestic drinking water standard in each of the sampling events <br />since 2003. High TDS waters are typically hard and have poor quality for drinking. <br />TDS in well MW -03 exceeded the NPL in three consecutive events beginning in October <br />2011. TDS concentrations at MW -04 exceeded the NPL in two of the three previous <br />events. Therefore, quarterly sampling for TDS has been re- initiated at all wells <br />The DRMS sent a letter to Mr. Brian McGill of GCC dated December 8, 2009. The letter <br />presented NPLs for groundwater monitoring for four parameters (TDS, Sulfate, Radium <br />226, and Radium 228). The letter presents an approach for evaluation of potential of <br />exceedences, and subsequent actions, based on results from the groundwater monitoring <br />program. The following approach was presented. <br />"Sampling for each well will be conducted semi annually and results to be submitted <br />annually. If an upward trend above the set limits is noted, the frequency of sampling will <br />increase to quarterly. If the upward trend still continues, the frequency of sampling will be <br />conducted monthly. If two consecutive monthly samplings still show an upward trend, GCC <br />will present a remedial action to the Division, which will indentify the source of the upward <br />trend and submit the actions GCC proposes to take a receive written approval from the <br />Division." <br />TDS concentrations at well MW -03 have defined an upward trend, with three consecutive <br />data points exceeding the NPLs. No data was obtained for TDS in the current sampling <br />event at MW -03. TDS concentrations at well MW -04 have fluctuated around the NPL, <br />though no clear trend is apparent. <br />No trend is defined above NPLs for sulfate in well MW -03, as only one exceedence has <br />been reported. Prior to April 2011, TDS and sulfate results were characterized by <br />alternating highs and lows that were likely associated with seasonal groundwater <br />fluctuations. Recent TDS highs have been recorded during October sampling events that <br />3 <br />