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The Request identifies previous pump test activities that have been conducted at the site. <br />These activities should be fully described so as to inform the need for this test, and the possible <br />need for additional monitoring and baseline characterization information prior to commencing any <br />activities. Further, the Request indicates that the A2 Sand is the primary (70%) formation for <br />uranium. However, it also appears that the confining layers between the A2 and WE, and the WE <br />and B, are one foot or less. Powertech should be required to demonstrate that this barrier is <br />sufficient to protect adjacent aquifers and the hydrologic balance during the proposed pump test. <br />Also, Powertech asserts that the criteria for "significant" hydraulic connection between the <br />production zone and overlying/underlying sands will be drawdown greater than 2.4 inches. <br />Powertech should be required to fully justify its reliance on this number. <br />Lastly, with respect to water storage above ground in the Baker tanks, there is no time line <br />for the length of time needed for storage. As colder weather is steadily approaching the proposed <br />pump test area, measures should be in place to ensure that above-ground piping and water <br />conveyances will not be subject to freezing or failure as a result. <br />Overall, there is insufficient data and plans to properly and comprehensively evaluate the <br />Request for Modification. Powertech refers to the fact that it has applied for an Underground <br />Injection Control (UIC) permit from the EPA with respect to this proposal. The Division should <br />work closely with EPA to ensure coordination of the agencies' respective programs, and make sure <br />that all information requests from either agency are incorporated into each agency's review. <br />Conclusion <br />Based on the foregoing, Powertech's submittal does not comply with the MLRA's <br />requirements regarding baseline characterization, as enacted through BB 08-1161. Lastly, there are <br />numerous deficiencies in the information presented relating to the impacts to groundwater and the <br />hydrologic balance at the site. <br />We look forward to your prompt attention on this matter. Please do not hesitate to contact <br />me directly with any questions. <br />Sincerely, <br />effrey C. Parsons, Esq. <br />Senior Attorney <br />Western Mining Action Project <br />On behalf of CARD, Environment Colorado, Clean Water Action, and INFORM <br />6