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6. Groundwater point of compliance: TDS measured at DCAL -02, in the Dry Creek <br />alluvium was well below the compliance standard of 3,195 mg 11. <br />7. Springs: Flow was higher than average at all of the monitored springs. TDS <br />shows an increasing trend at all of the springs except the spring (S50) near the <br />damaged wells at Pond 016, the Smith water supply on Hubberson Gulch (S7), <br />and the spoils spring (S5) near drainage PM -2 above Pond 016. Water quality in <br />all of the springs is consistent with irrigation standards. <br />7. Surface water flows were above average at all monitoring locations, again this is <br />due to exceptionally high snowpack and heavy spring precipitation of 2011. <br />8. Surface water quality: Receiving stream standards were exceeded on some <br />occasions, as outlined in SCC's report. <br />a. Iron limits were exceeded on seven occasions, mostly during spring <br />runoff. SCC notes that premining iron levels were generally in excess of <br />the standards for iron, and that the standards have since been revised <br />based on ambient conditions prior to mining, so it is likely that future <br />monitoring of average conditions will be in compliance with receiving <br />stream standards for iron. <br />b. Mercury limits were exceeded one time on the downstream Sage Creek <br />site. SCC believes this to be an anomaly, which is likely, based on prior <br />monitoring data at this site. <br />C. Selenium was in excess of the receiving stream standard on five <br />occasions at pond outfalls. Four of the excursions were at Pond 017, and <br />SCC reports that they are currently on a Compliance Schedule with <br />CDPHE to meet the selenium limit by December 31, 2015. The other <br />exceedance, at Pond 016, is discussed below. <br />9. TDS values at stream monitoring locations show a generally increasing trend. <br />On Hubberson Gulch and Dry Creek, TDS values are below predicted values. <br />On Sage Creek, TDS averages 940 mg /1, which is above the predicted value of <br />676 mg /1. SCC notes that the maximum TDS level in the two outfalls discharging <br />to Sage Creek was 480 mg /1. There are no spoil springs draining to Sage Creek <br />and very little disturbed area contributes to the watershed, so it would not appear <br />that this increase is due to mine - related influences. <br />10. One NPDES effluent limit was exceeded in 2011; selenium was reported at 4.8 <br />ug /I (limit is 4.6 ug /1), but SCC notes that total recoverable selenium was <br />analyzed at 3.9 ug /1. SCC further contends that their CDPS permit states that <br />this standard is "not to be exceeded more than once every three years on the <br />average" and the data show that the standard has not been exceeded in the six <br />years prior to this excursion or since then. <br />