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Letter to Richard Blubaugh 2 September 25, 2009 <br />Centennial Project Receipt of Modification MD-03 File No. P-2008-043 <br />5. Provide details on the fence to be installed around the pump test facilities. These details are needed both <br />to evaluate the effectiveness of the fence to prevent wildlife and livestock access and. to estimate the cost of <br />removal of the fence to be included in the amount of reclamation bond to be required. <br />6. The Section 33 Pumping Test Plan included with MD-03 states on page 5 that the monitoring wells will be <br />located spatially in order to define the regional potentiometric gradients in the Laramie Formation, A2 Sand, <br />and B Sand. Initial measurements for this purpose must be collected and the data provided to the DRMS <br />prior to commencement of the proposed pumping test. These initial measurements, which may be single <br />hand tagged measurements, if not already done should be taken as soon as possible, and are in addition to the <br />baseline ground water level data to be collected over a 72- to 96-hour period prior to initiation of pump <br />testing as described on page 6 of the Pumping Test Plan. <br />7. The Section 33 Pumping Test Plan included with MD-03 describes on page 5 well drilling and completion <br />for the wells to be used in the proposed pumping test. DRMS requires submittal of completion and <br />development reports for all wells. Critical to DRMS review are the geophysical logs and drilling/mud logs <br />and Powertech's interpretation of their relation to the stratigraphy. <br />8. The Section 33 Pumping Test Plan states on page 5 that the locations of the pumping well and monitoring <br />wells installed for and used in previous pumping tests conducted by Powertech "are shown on Figure 4." <br />These wells are not shown on the Figure 4 provided to the DRMS. Since these wells are going to be <br />monitored in the pumping test proposed in MD-02, a map showing their location must be provided. The <br />information listed in item no. 7 above must also be provided for these wells. <br />9. Has core hole IN-14-33 been drilled? If so, provide and detailed description of the core including the <br />results of any geotechnical testing conducted, and provide the plugging and abandonment report for the hole. <br />If not, depending on the degree of confidence that can be assigned to the aquifer/aquitard relationship <br />interpretations from data taken from the other holes drilled in section 33, DRMS may require that hole IN- <br />14-33 be cored, evaluated, and plugged prior to approval of MD-03. <br />10. The Section 33 Pumping Test Plan states on page 7 that the Aquifer Test software distributed by <br />Waterloo Hydrogeologic will be used to analyze pump test data; provide the version number for the software <br />that will be used. <br />11. Discussion on page 8 of the Section 33 Pumping Test Plan under the heading "Produced Water Disposal" <br />raises the following issues: <br />a. The Pumping Test Plan states that Powertech will demonstrate through Mechanical Integrity Testing that <br />there is no potential for injectate to flow from the well into the Laramie Formation where the well passes <br />through that formation. MD-03 lacks discussion of how it will be assured and demonstrated that injectate <br />will not flow into strata above or below the injection well screened strata after it is discharged to that <br />strata, via either natural or manmade (e.g. other wells) pathways. <br />b. The Pumping Test Plan states that the injection well is not expected to be operated under pressure, but <br />allows that the injection might be pressurized as needed. If the injection is pressurized, the potential for