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DRMS, MD-02 <br />April 14, 2009 <br />wells for the initial pumping tests. Powertech is simply following the procedure that is <br />available to it in the State of Colorado to conduct baseline characterization, that is, via the <br />notice of intent to conduct prospecting. In fact, Powertech was told by a DRMS <br />representative that it had followed the proper protocol by presenting and reviewing the SAP <br />with DRMS prior to commencing its baseline characterization activities. With regard to the <br />activities specifically proposed under MD-02, Powertech met with DRMS on March 31, 2009 <br />to review the details of the pumping test. Regrettably, DRMS chose to issue its request for <br />additional information prior to this presentation. If the concept of "grandfathering" has any <br />validity at all, the baseline characterization activities for the proposed Centennial Project <br />should be so considered. <br />Issue #3: The third issue postulated by Mr. Parsons is "whether the Request for <br />Modification contains sufficient information for the Division of Reclamation, Mining & <br />Safety (DRMS) to assess the impacts of the proposed activities with respect to soil and <br />ground water impacts." <br />Powertech provided the information the DRMS requested in MD-02. Powertech proceeded <br />with the understanding the DRMS staff had requested sufficient information to adequately <br />review and approve the modification. Based on the March 31, 2009 request for additional <br />information, it appears that there was a misunderstanding about what was required. <br />Powertech is assured by its own experts and outside consultants that there would be no <br />impacts to groundwater in the uppermost aquifer. Nevertheless, in this particular situation, <br />Powertech is willing to do some additional work and commit to a change in the proposed <br />handling and disposal of the pumped native groundwater. Therefore, Powertech will propose <br />in its finalized Pumping Test Plan an alternative that will not present any perceived or <br />potential threats to the uppermost aquifer. <br />On a related matter, Powertech is not aware of the statute or regulation that provides for <br />public comments on a Notice of Intent to Conduct Prospecting activities. While we are not <br />formally objecting, at this time, we seek from the DRMS some explanation or clarification of <br />the authority that exists for such comments to be submitted at this stage of the process. <br />Lastly, Powertech wishes to take this opportunity to express our appreciation to the staff of <br />DRMS for the assistance and cooperation extended to Powertech as it seeks the information <br />vital to preparation of the permit application required for development of its proposed <br />Centennial Project. <br />Res tfully yours <br />/ G 1 <br />Richard E. Blubaugh <br />Vice President - Environmental Health & Safety Resources <br />Enclosure <br />cc: T. Walsh, <br />W. Mays, <br />R. Clement <br />J. Fognani, Esq.